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Technical services: withholding tax

Stuart Rogers and Chris Harrison (PKF Francis Clark) answer a query on the position of a UK company regarding the deductibility of local withholding taxes on the provision of international consultancy services.
 

Question

 
My client is a UK company providing consultancy services to a variety of clients all around the world. Certain customers deduct local withholding taxes before making payment. Are these deductions permissible and can my client get a refund or a credit for the foreign tax suffered?
 

Answer

 
Under the domestic law of some countries a company may be required to deduct withholding tax from payments to suppliers for the provision of ‘technical services’ in the same way that withholding tax can be deducted on dividends interest and royalties.
 
Technical services will...

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