In some tax jurisdictions, dividends to owners and other payments (e.g., interest, royalty, or license payments) may trigger a tax obligation to the tax authority in the payor’s jurisdiction (sometimes referred to as a “withholding tax”). Such a tax may be required to be withheld from the payment by the payor and remitted to the taxing authority. It is not always clear whether the payor or the recipient should account for the tax as an income tax, and careful consideration is often required.
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This publication provides comprehensive guidance; however, it does not address all possible fact patterns, and the guidance is subject to change. Consult a Deloitte & Touche LLP professional regarding your specific issues and questions.