Payments that are Subject to Withholding Tax

Key requirements

Covered categories include debt-related interest, royalties, knowledge or assistance, management fees and movable-property rent. Interest on overdue trade accounts is not automatically exempt merely because it relates to a goods sale. Software and digitised goods use a rights-based characterisation, distinguishing rights exploited from ordinary copyrighted products. Service performance location and treaty provisions can also affect the result. Analyse the contract, intellectual property rights and activities actually performed rather than applying one rate to every overseas invoice. The source sets out detailed exceptions and FAQs for the specific category.