On the basis of these facts, you ask for confirmation that entity A is required to submit the agreement in paragraph 78, paragraph 1, point b) (i) to Company B; that the withholding tax rate is 4% and that no withholding tax should be paid if Company A actually pays the interest to Company C. Paragraph 78, paragraph 1, point b), requires that the agreement … be the subject and the person who incurred the costs… In your situation, the unpaid amount is an interest charge for year 1 due by Company A to Company B. Therefore, the agreement must be presented on the basis of paragraph 78, paragraph 1, point b), between the subject (entity A) and that person (Company B). (i) the outstanding amount is considered to be paid by the insured and received from that person on the first day of that third fiscal year, and Section 153, with the exception of Section 153, paragraph 3, applies to the extent that it would be applicable if that amount was paid by the subject to that person and, in any event, with accrued but unpaid interest. Model 78 (1) Where an amount relating to a deductible expense or expenses attributable by a person with whom the subject was not involved at the time of the imputation or expenses and, at the end of the second fiscal year following the fiscal year in which expenses or expenses are incurred, the payment is made at the end of that second fiscal year (3) when the tax year , for an amount covered by section 78, paragraph 1, attributable to a person`s subject, an agreement is made in a prescribed form for the purposes of this section, after the date on which the agreement under paragraph 78, paragraph 1, point b) is to be filed. , the two paragraphs 78, paragraph 1, points (a) and b) apply to this amount, except that paragraph 78, paragraph 1, point a), must be interpreted in the sense that only 25% of this amount must be included in the calculation of the tax payer`s income. 4. Is an amount for the expenses of a taxpayer constituting a supplementary pension or a superannuation allowance is a rest allowance, salary, salary or other allowance (excluding leave or reasonable leave benefits or an amount deferred under a wage deferral agreement) for an office or employment on the day of the end of 180 days after the end of the tax year in which the expenses are incurred Not paid? For the purposes of this Act, the amount that was not borne during the year is considered to be a charge in the fiscal year in which the amount is paid. Position: The agreement must be submitted to the same person as the costs are incurred. Therefore, in this case, the withholding rate at source is 4% for 2009 and the actual payment to the tax-transparent company is not subject to withholding tax.