In previous articles discussing the Budget 2012 foreign affiliate "dumping" and shareholders loan rules (see, for example, Budget 2012 Legislation – More Revisions to Foreign Affiliate "Dumping" and Shareholders Loan Rules in our November 16, 2012 issue), we discussed the interest imputation rules for pertinent loan or indebtedness (PLOI) to non-residents. In particular, we noted the submissions made that the interest imputed under section 17.1 for a PLOI was too high. The Canada Revenue Agency website has been updated recently to include the prescribed interest rate applicable to the deemed interest income provision. The rate can be found on this page.
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