The withholding tax regime and treaty clearances

INTM413210 outlined the ITA07/S874‘withholding tax’ implications of paying yearly interest overseas, and how a valid application by an overseas lender under the relevant double taxation agreement would affect that obligation.

An application by the overseas lender under a DTA or under the EU Interest & Royalties Directive (INTM400000), is likely to be made up of two elements, depending largely on how promptly the claim follows the making of the loan. These are:

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