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Article 45 Withholding Tax changed

1. The following income earned in the State by a non-resident person shall be subject to Withholding Tax tax at the a rate of 0% (zero percent) (0%) zero percent in form of withholding tax, or at any other rate as specified in for withholding tax to be determined by a decision issued by Cabinet resolution upon the Cabinet at the suggestion proposal of the Minister: Minister, to the extent that such income is not attributable to a permanent establishment or a connection in accordance with the provisions of Paragraph (A) or Paragraph (C) of Clause (3) of Article (12) of this Decree-Law.

a) The 2. As an exception to Clause (1) of this Article, the Cabinet may issue a resolution upon a proposal of the Minister to determine categories of State Sourced Income derived by a Non-Resident Person as prescribed income earned in the decision issued by the Cabinet pursuant State subject to this Article, insofar such income is not attributable to a Permanent Establishment of the Non-Resident Person withholding tax at rates specified in the State. that resolution.

b) Any 3. The Cabinet may issue a resolution upon a proposal of the Minister to determine any other income as subject to withholding tax at rates specified in a decision issued by the Cabinet at the suggestion of the Minister. that resolution.

2. 4. The Withholding Tax withholding tax that is payable under Clause 1 of this Article shall be deducted from the gross total amount of the payment and remitted paid to FTA in accordance with the Authority in the form forms and manner procedures and within the timeline prescribed period specified by FTA. The FTA may add controls or conditions for the Authority. purposes of implementing the provisions of this Clause.

Article 46 Withholding Tax Credit changed

1. If a Person person becomes subject to tax during a Taxable Person in a Tax Period, taxation period, the Person’s Corporate Tax due corporate tax payable under Article 3 (3) of this Decree-Law can may be reduced by an amount equal to the amount of Withholding Tax Credit the withholding tax credit for that Tax Period. the same taxation period.

2. The maximum Withholding Tax Credit withholding tax credit under this Decree-Law is shall be the lower of: lesser of the following:

a) a. The amount of Withholding Tax withholding tax deducted under Clause 2 (4) of Article 45 (45) of this Decree-Law.

b) b. The Corporate Tax due amount of corporate tax payable under this Decree-Law.

3. Any The excess Withholding Tax Credit withholding tax credit for a Tax Period the taxation period arising as a result of the application of Clause 2 (2) of this Article shall be refunded to the Taxable Person taxpayer, in accordance with Article 49 (49) of this Decree-Law.