https://www.taxtmi.com/caselaws?id=796792 Interest paid to a foreign bank's Swedish branch attracted withholding tax because branch-level taxation on profits did not make the branch a Swedish treaty resident. The applicable treaty analysis concerned the bank's Netherlands residence, and a claimed bona fide belief in Swedish treaty eligibility failed where the residency certificate was incorrect and the non-withholding position had been disputed. Interest paid to another foreign bank also required withholding because its Swedish tax residency certificate was issued after payment and no contemporaneous evidence established residence at the relevant time. A later certificate cannot substantiate a payer's bona fide basis for non-withholding. en-us Tue, 06 Jan 2026 00:00:00 +0530 Tue, 11 Aug 2026 08:47:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=796792 Interest paid to a foreign bank's Swedish branch attracted withholding tax because branch-level taxation on profits did not make the branch a Swedish treaty resident. The applicable treaty analysis concerned the bank's Netherlands residence, and a claimed bona fide belief in Swedish treaty eligibility failed where the residency certificate was incorrect and the non-withholding position had been disputed. Interest paid to another foreign bank also required withholding because its Swedish tax residency certificate was issued after payment and no contemporaneous evidence established residence at the relevant time. A later certificate cannot substantiate a payer's bona fide basis for non-withholding. Case-Laws Income Tax Tue, 06 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796792