Foreign institutional investor withholding requires deduction on specified security income, subject to qualifying lower treaty rates and certification.

Withholding tax applies to income in respect of securities identified under section 210(1) when payable or credited to a Foreign Institutional Investor. Any person responsible for payment must deduct tax at the earlier of credit or payment, with no monetary threshold. Tax is deductible at 20 per cent, subject to application of a lower rate under an agreement referred to in section 159 where the investor is entitled to that benefit and furnishes the prescribed certificate.

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