The Tax Court of Canada gave its decision on 22 April 2008 in the case of Prévost Car Inc. v. Her Majesty the Queen (2008TCC231). In Prévost, a Canadian company paid dividends to a Netherlands company. The parties argued that the lower treaty rate of 5% should apply pursuant to Art. 10(2) of the Canda-Netherlands tax treaty. The tax authorities argued that the treaty did not apply as the Netherlan…