Dogmatix

This woman's crooked grin is too much for me along with the conflict of interest inherent in her providing tax advise to persuade people to buy the cards, while working for an agent that makes its living from selling Thai Elite/Privilege cards.

Mazars observation "The Revenue Department appears to be aware of the challenges encountered by taxpayers from the new protocol concerning foreign-sourced income. DI Paw. 162 resolves the difficulties taxpayers may have in distinguishing assessable income and savings incurred in years before 1 January 2024. Taxpayers with foreign-sourced income, which has yet to be realised, should consider realising income or gains before the end of this year so that such foreign-sourced income will not be taxable if remitted into Thailand on or after 1 January 2024" That's a very polite way of putting it. More realistically the director general of of the RD issued the first order impulsively without thinking it through, with no idea of how much incremental tax it would raise, if any, certainly no concern about potential impacts on the Thai economy, condo developers, or any details of how it would be applied vis a vis DTAs or anything much else. He was just told by underlings it was a good idea because CRS reporting will help them catch out cheaters. Instead of passing it by the RD lawyers beforehand I guess the legal department only found out about it from the press and have spent the last couple of months giving it the once over. One very obvious conclusion must have been that the impossibility of setting any fair guidelines for determining what constituted capital and what constituted income going back decades in some cases would probably have resulted in a plethora of cases in the Central Tax Court which the RD could very well have lost. This is in addition to the fact that no legislative support has been forthcoming from the finance ministry under Srettha as finance minister, who has probably only set foot in the building to pray at the spirit house and is just leaving everything to the bureaucrats like the RD director general with zero ministerial input or oversight. This means that the new interpretation will start life on 1 Man 2024 as a mere instruction to RD staff that is not binding on taxpayers. The risk remains that wealthy taxpayers will refuse to accept the unlawful reinterpretation and sue in the Tax Court even with the pre 2024 amnesty. The fact that this new interpretation is totally inconsistent with PT's previous policy of regional tax competitiveness under Yingluck doesn't even seem to have registered while PT is so busy trying to dig itself out of its digital vote buying pledge. The Yingluck government did a good job in making Thai corporate income tax competitive with HK and Singapore by reducing it from 30% 20%. So why ruin that by making it unattractive for anyone to come and work, retire or invest as an individual in Thailand? If regional taxation competitiveness, is no longer a policy of PT, why not go the whole hog and raise corporate income tax back up to 30%? While this new remittance tax for individuals may only raise 10s of billions in incremental tax, if that, raising corporate income tax back to 30% would raise an incremental 300 billion, 60% of what they estimate is needed for the digital wallet, without any negative effect on the poor like an increase in VAT which is no doubt in Thailand's not too distant future. The Prachachart Thurakit article suggested that amnestying pre 2024 income was just a stop gap and that legislation is planned to amend the Revenue Code to introduce global taxation of income whether remitted to Thailand or not. I would guess that PT finance functionaries, while not busy thinking up schemes to renege on the digital wallet and blame that on someone else, are probably thinking they can kick this can down the road. Since they have left it all to the RD without the party taking full ownership of the policy, they keep their options open to either provide supporting legislation to amend the Revenue Code via a Royal Decree or even a parliamentary bill or to ditch the whole thing, if it proves too troublesome and blame it on the Revenue Department for failing to take into account the impacts on the Thai economy in the same way as they scrapped the transactional tax on SET stock trades and blamed the Finance Ministry for failing to understand the negative implications for market volumes. If it is successfully challenged in the Tax Court, they will be forced to take a stand but this government will probably be gone before that happens. I guess the RD will just leave it like this for now, since the orginal order came from the top of the RD and their lawyers have now had time to think about it and Order P 162/2566 was all that resulted from this process, welcome though that was. Other details like how to apply tax credits will be filled in later, possibly after problems become apparent following the submission of 2024 tax returns which will only be the tip of the iceberg since prior year income for 2024 will now no longer be a thorny issue. While the UK HMRC has pages and pages of guidelines on taxation of remitted foreign source income for its non-doms, Thailand's RD is happy to introduce a similar tax with a 50 word instruction to staff that is not binding on taxpayers and wait and see where the gremlins appear. Spot the Mickey Mouse tax authority,

Indeed. The first prediction in the artilce this that the RD would amnesty income generated before 2024 has already come to pass.

Worth bearing in mind that she is an agent selling Thai Privilege memberships on commission. That's why she is smiling so much.

Interesting that the police will not be involved in any of this. I wonder if Chada and any of his family, such as his son in law, a mayor who was just arrested for extortion, are on any of these lists. It all sounds like a nice little earner. You are on the red list and the DOPA SWAT team is coming for you next Tuesday. Let's play high stakes golf for a few million a hole and I promise you my golf is really bad.

A Thai friend who is a shooting enthusiast looked into this when Anutin first announced he planned to do this several weeks ago. He believes Anutin can only stop provincial governors from issuing Por 12 carry licences that are valid in their own provinces only. The police chief approves the Bkk and nationwide permits and the Council of State has already ruled that the Interior Ministry has no right to interfere with this when the Interior Ministry under the Yingluck government tried to block the issue of carry permits approved by the police chief. There are only around 1,000 nationwide carry permits and nearly all are issued to MPs, senators, judges and the like with less than around 50 in the hands of very wealthy businessmen. The MPs, senators and privy councillors will quickly make a big fuss, if their annual permits cannot be renewed. I don't think provincial carry permits have been issued in recent years. Certainly none for Bkk only and I don't think the elected governor has that authority anyway. I believe provincial governors have not wanted to take the risk of issuing permits in case a crime is committed by some one approved by then and there is high risk provincial permit holders will violate their licences and carry their guns over provincial boundaries. If someone thinks he is important enough to get one, he can be told to apply to the national police chief for a more useful nationwide permit. Imagine having a permit for Samut Prakan or somewhere and you gun becomes illegal each time you cross a provincial boundary. At first he said he would change the law to discontinue carry permits completely but asking MPs, who are probably the largest single group of civilian legal concealed gun carriers, to vote for it would be like asking turkeys to vote for Christmas. It is notable that these news from the Interior Ministry was not accompanied by any statistics regarding the number of carry permits in issue and the types of people they are issued to. Without any analysis of that type it sounds as if significant steps are being taken to reduce the number of guns legally on the streets but the reality is that it will take a very small number of guns out of the hands of a few senior members of society, assuming they don't just continue to carry their guns anyway in the knowledge that no cop would dare arrest them. Meanwhile a large number of the estimated 4 million unregistered guns will continue to be carried around by their owners.

She can also check in at the Police General Hospital and catch up her cosmetic surgery at taxpayer expense for a few months while waiting for release. The last time I saw her she looked very good for her age but a wee bit flat chested. The photograph above suggests the need for a light face lift.

'...Srettha is definitely obliged to return favours to Yingluck..." When Yingluck was PM there were a lot of rumours in the press about favours Srettha allegedly received from Yingluck. I wonder if he is still anxious to receive more of them over 10 years later.

He is just a grinning Cheshire cat nominee for the person who stole the election.

If it was a blank gun and not modified to fire real bullets, there is no law against them yet as far as I know, even though the Interior Ministry has been seizing them and asking owners to register them since the Paragon murders by the 14 year old fruit cake. It takes some time to amend laws in Thailand. They need draft a bill first which needs to pass three readings in parliament and then usually comes into effect 90 days after publication in the Royal Gazette.

Like many aspects of Thai tax this is fairly opaque. I believe "commercial or profitable manner" wording is to distinguish from property acquired through inheritance or not for profit which is exempt. I have no idea how property qualifies as acquired not for profit in addition to inherited property. I would suggest that this category is probably redundant. Property sales are taxed at source at the Land Office and, similarly to tax withheld from dividends, there is no need to declare sales on the tax return form, if tax withheld was correct. I think the reason to declare property sales is in the case of the land sale involving Sansiri that was flagged by Chuvit. In that case the sellers owned the land jointly and broke up the sale into a number of transactions of several days with the Land Department charging the regular withholding tax applicable to individuals. However, corporations have to pay normal corporate income tax and partnerships have to pay tax at the normal income tax progressive rates after deduction of allowable expenses for which there is a space on the form. In the Sansiri case, Chuvit argued that the Revenue Code regarded joint sellers as a partnership and therefore they should have have paid at the top progressive rate of 35% on the gains instead of getting away with the withholding tax which would have been less than 5% of the sales value. So if you are filing a PND 90 as a partnership, you should declare gains on property sales and claim expenses there. Income tax paid withheld at the Land Dept should be entered under the tax paid section. Thus, if you have a substantial gain like the sellers in the Sansiri case, you will have to pay more tax and vice versa, if you had a small gain or a loss. Normal individuals don't have to fill in this section in respect of sales of Thai property because the withholding tax at the Land Office is final for them.

I am curious as to how the exclusion of 6 million people works. Less than 4 million pay income tax which starts at 25k per month net of basic deductions. So excluding everyone in the tax net is still short by over 2 million people. So they must be confident there are several million people with extremely low incomes who have over 500,000 in the bank. If this is really true, they should investigate all of them for income tax evasion.

I have seen two of his videos recently and he seems like a BS merchant. He also can't read a word of Thai which puts him at a disadvantage in having to rely on translations of complex Thai legal documents.

Anurak has a positive meaning something like conservation.

The article quotes from varying sources and is suggestive of a work still in progress but also that they have come around to the view that taxing income that arose prior to 1 Jan 2024 may be more trouble than it is worth. Two things spring to mind. 1. If they really intend to make 1 Jan 2024 a start date for something, they will need a Royal Decree. Order P. 161/2566 will need to be rescinded and the lawyers will have pointed out to them it wasn't legally binding on taxpayers anyway. A Royal Decree will need cabinet approval and there may be some differences of opinion in the coalition parties which could change things. Talking about 1 Jan 2024 with any luck will just turn out to be a face saver for the DG of the RD, who seems to have acted like a bit of a nincompoop anyway (albeit no doubt with a nod from finance minister Srettha who was about to hop on the plane to NY at the time) as it would probably be tough to get out a Royal Decree by then and Thailand very rarely makes any law retroactive. 2. Amending the Revenue Code in parliament to introduce global taxation would actually be a more logical step than trying to tax foreign source income on a remittance basis. My guess is that's where we are ultimately headed, either during the term of this government or an MFP government, if they manage to gain power. But it would be a major undertaking and would easily take two years to draft and go through all 3 readings in parliament. They might want to reform other aspects of the law as well. . There are many legit arguments against global taxation or a remittance, as raised by Prof Kittipong, former chairman of Baker McKenzie. In addition there are many corrupt politicians and bureaucrats with wealth offshore who might oppose global taxation or remittance tax. From the macro perspective Thailand has fallen into the middle income trap and has no way to crawl out to become a high income country like Singapore because there is far too much incompetence and corruption in government. Without those two handmaidens Thailand could strive to be a regional finance centre with a liberal tax regime like Singapore, as suggested by Prof Kittipong. But that would require enlightened governance and a commitment to improving public education and doing whatever it takes to make Thailand competitive in this post sweated labour phase and thus fulfill it long term sustainable growth potential which is far higher than the 2-3% GDP growth which is now the best it can do. With faster growth the tax take would increase without raising taxes. As it is, Thais have started to expect a developed country welfare state without first becoming a developed economy. That means raising taxes across the board, including VAT.

An article in yesterday's Prachachart Thurakit suggests the RD is starting to walk this back a bit but not giving up on it https://www.prachachat.net/finance/news-1432180?fbclid=IwAR0FtCbDVifNc-atDT8uHGklrCLP5PNOva3VrsaHFX9W_kjEm-bKQBnqEKc . It sounds like they are planning to exempt all foreign source income earned before 1 January 2024. It also sounds like they are thinking of moving to a global taxation model involving taxation of foreign source income in the year it arises, regardless of whether it is remitted to Thailand or not. They seem to have realised that that they need to amend the Revenue Code, which could take a couple of years, and not just let the RD issue a directive to staff that is not binding on taxpayers. However, they could still go for a stop gap solution to try to raise some more tax from income earned in 2024. The whole thing smacks of stupidity and incompetence from politicians and civil servants alike. If you want to make major changes to the tax regime, it needs careful study beforehand and then proper legislation in parliament, not just let a bureaucrat blurt out a nonsensical unlawful order and threaten everyone. Huge damage has already been done by that. At least they are likely to give expats more time to make arrangements to sell up and get out of the country. Here is a rough google translate. Stocks-Finance The Revenue Department delays "taxing" foreign income before 2024, adhering to the same criteria. November 9, 2023 - 6:32 a.m. levy taxes The Revenue Department has called in the capital market department to understand the tax collection methods from people who earn money abroad. which when imported must be subject to tax inspection No matter what year it was imported. Previously, imports over a year would not be taxed. After the announcement was made Many parties are still concerned about the lack of clarity. Permanent Secretary of the Treasury insists that loopholes must be closed. Mr. Lawan Saengsanit, Permanent Secretary of the Ministry of Finance, said that the Ministry of Finance has confirmed that there will definitely be taxation of income from foreign countries. The law will be amended to allow collection as soon as the money is received. Only, amending the law must pass through Parliament, so it probably won't be done quickly. But insist that you have to do it. Because it meets international criteria “People who have already paid taxes from abroad need not worry. Because you don't have to pay twice. But you must understand that In the past, there have been large companies that have used this channel to manage taxes. We have to close this gap.” Investors complain about riding elephants to catch grasshoppers. Mr. Anurak Bunsawaeng (Jo Luk Isaan), a major investor and former president of the Value Investors Association (Thailand), said that major investors Should be taxed at the personal income tax rate. The highest rate is 35%. Therefore, I believe that no one will definitely accept being taxed. Therefore, you may see large investors 1. Stop investing abroad. 2. Do not take money back to the country and 3. Use gray methods to find various loopholes, which will make the opportunity for the government to collect a lot of revenue from this tax probably not be possible. “It will definitely create a lot of problems. Because it will cause difficulties for investors. Including in practice through brokers Must collect documents for incoming and outgoing money. To separate profits to prove tax payments each year. which creates a lot of difficulties So it is like riding an elephant to catch grasshoppers. This means that taxes cannot be collected. Because the chance that there will be very few people willing to pay But it creates many negative effects. It's not just big investors. but also private funds or a group of magnates who invest money abroad.” Mr. Anurak said I want the government to change its perspective. Because it's not that investors don't want to pay taxes. But if taxes are collected at a reasonable rate or at the level of 10-15%, it is still acceptable. “Tax collection should require people to act honestly. But if you keep it that high I believe that there will definitely be a lot of corruption. Right now, I mostly invest in China, Vietnam, and the United States, and have prepared several defensive plans.” Begin to charge money from 2024. However, recently there was a report from the Revenue Department that It has been concluded that In the first phase, there will be relief in the case of income generated abroad before 2024, if it is not imported within the same tax year as the year in which the income was generated. It will not have to be checked. Because finding document evidence will be difficult. It is considered to be releasing the ghost. “Income generated before 2024 will use the old rules. That is, if it is not imported in the same tax year. The department will not collect it. As for imports across the year, they are no longer collected according to the original criteria. But income generated abroad from January 1, 2024 onwards, imported at any time will be subject to tax. In the future, Section 41 of the Revenue Code will be amended to immediately calculate tax in the year in which income is earned abroad. Regardless of whether money is brought into the country or not, however, it may take 1-2 years to amend the law.” Set "Pichai" to see private offers Special Professor Kitipong Urapeepattanaphong, director of the Stock Exchange of Thailand (SET) and former chairman of the board of Baker & McKenzie Company Limited, told "Prachachat Turakij" that the collection of such taxes is being developed. Let's discuss in order for the government to postpone enforcement for now Because I believe it's not worth it. It will affect the overall tax picture of Thailand as a whole. It is understood that now Mr. Settha Thavisin, Prime Minister and Minister of Finance, has assigned Mr. Pichai Chunhavajira, Advisor to the Prime Minister. is in charge of this matter “And according to the Revenue Department Order No. 161/2023 that was issued, it is a practice. It cannot be interpreted outside of the law. Therefore, if such taxes are to be collected The tax structure must be restructured. which is a big deal The law must be amended, repealed Section 41, paragraph two, and issued a new law in its place. In the future, taxes will be collected similar to the United States. That is, all income in this world must be taxed. But in general, taxes should not exceed 15%.” The Revenue Department announces income from abroad over the year must be taxed starting 1 Jan. 2024. Revenue Department discusses new order “Income earned from abroad over the year” is subject to tax. Is collecting foreign investment tax worth it? Question from "Kitipong Urapeepattanapong" tax law guru

An article in yesterday's Prachachart Thurakit suggests the RD is starting to walk this back a bit but not giving up on it https://www.prachachat.net/finance/news-1432180?fbclid=IwAR0FtCbDVifNc-atDT8uHGklrCLP5PNOva3VrsaHFX9W_kjEm-bKQBnqEKc . It sounds like they are planning to exempt all foreign source income earned before 1 January 2024. It also sounds like they are thinking of moving to a global taxation model involving taxation of foreign source income in the year it arises, regardless of whether it is remitted to Thailand or not. They seem to have realised that that they need to amend the Revenue Code, which could take a couple of years, and not just let the RD issue a directive to staff that is not binding on taxpayers. However, they could still go for a stop gap solution to try to raise some more tax from income earned in 2024. The whole thing smacks of stupidity and incompetence from politicians and civil servants alike. If you want to make major changes to the tax regime, it needs careful study beforehand and then proper legislation in parliament, not just let a bureaucrat blurt out a nonsensical unlawful order and threaten everyone. Huge damage has already been done by that. At least they are likely to give expats more time to make arrangements to sell up and get out of the country. Here is a rough google translate. Stocks-Finance The Revenue Department delays "taxing" foreign income before 2024, adhering to the same criteria. November 9, 2023 - 6:32 a.m. levy taxes The Revenue Department has called in the capital market department to understand the tax collection methods from people who earn money abroad. which when imported must be subject to tax inspection No matter what year it was imported. Previously, imports over a year would not be taxed. After the announcement was made Many parties are still concerned about the lack of clarity. Permanent Secretary of the Treasury insists that loopholes must be closed. Mr. Lawan Saengsanit, Permanent Secretary of the Ministry of Finance, said that the Ministry of Finance has confirmed that there will definitely be taxation of income from foreign countries. The law will be amended to allow collection as soon as the money is received. Only, amending the law must pass through Parliament, so it probably won't be done quickly. But insist that you have to do it. Because it meets international criteria “People who have already paid taxes from abroad need not worry. Because you don't have to pay twice. But you must understand that In the past, there have been large companies that have used this channel to manage taxes. We have to close this gap.” Investors complain about riding elephants to catch grasshoppers. Mr. Anurak Bunsawaeng (Jo Luk Isaan), a major investor and former president of the Value Investors Association (Thailand), said that major investors Should be taxed at the personal income tax rate. The highest rate is 35%. Therefore, I believe that no one will definitely accept being taxed. Therefore, you may see large investors 1. Stop investing abroad. 2. Do not take money back to the country and 3. Use gray methods to find various loopholes, which will make the opportunity for the government to collect a lot of revenue from this tax probably not be possible. “It will definitely create a lot of problems. Because it will cause difficulties for investors. Including in practice through brokers Must collect documents for incoming and outgoing money. To separate profits to prove tax payments each year. which creates a lot of difficulties So it is like riding an elephant to catch grasshoppers. This means that taxes cannot be collected. Because the chance that there will be very few people willing to pay But it creates many negative effects. It's not just big investors. but also private funds or a group of magnates who invest money abroad.” Mr. Anurak said I want the government to change its perspective. Because it's not that investors don't want to pay taxes. But if taxes are collected at a reasonable rate or at the level of 10-15%, it is still acceptable. “Tax collection should require people to act honestly. But if you keep it that high I believe that there will definitely be a lot of corruption. Right now, I mostly invest in China, Vietnam, and the United States, and have prepared several defensive plans.” Begin to charge money from 2024. However, recently there was a report from the Revenue Department that It has been concluded that In the first phase, there will be relief in the case of income generated abroad before 2024, if it is not imported within the same tax year as the year in which the income was generated. It will not have to be checked. Because finding document evidence will be difficult. It is considered to be releasing the ghost. “Income generated before 2024 will use the old rules. That is, if it is not imported in the same tax year. The department will not collect it. As for imports across the year, they are no longer collected according to the original criteria. But income generated abroad from January 1, 2024 onwards, imported at any time will be subject to tax. In the future, Section 41 of the Revenue Code will be amended to immediately calculate tax in the year in which income is earned abroad. Regardless of whether money is brought into the country or not, however, it may take 1-2 years to amend the law.” Set "Pichai" to see private offers Special Professor Kitipong Urapeepattanaphong, director of the Stock Exchange of Thailand (SET) and former chairman of the board of Baker & McKenzie Company Limited, told "Prachachat Turakij" that the collection of such taxes is being developed. Let's discuss in order for the government to postpone enforcement for now Because I believe it's not worth it. It will affect the overall tax picture of Thailand as a whole. It is understood that now Mr. Settha Thavisin, Prime Minister and Minister of Finance, has assigned Mr. Pichai Chunhavajira, Advisor to the Prime Minister. is in charge of this matter “And according to the Revenue Department Order No. 161/2023 that was issued, it is a practice. It cannot be interpreted outside of the law. Therefore, if such taxes are to be collected The tax structure must be restructured. which is a big deal The law must be amended, repealed Section 41, paragraph two, and issued a new law in its place. In the future, taxes will be collected similar to the United States. That is, all income in this world must be taxed. But in general, taxes should not exceed 15%.” The Revenue Department announces income from abroad over the year must be taxed starting 1 Jan. 2024. Revenue Department discusses new order “Income earned from abroad over the year” is subject to tax. Is collecting foreign investment tax worth it? Question from "Kitipong Urapeepattanapong" tax law guru

There are so many notable achievements it will be difficult to narrow down the list. Let's give it a try anyway. 1. Stealing the election. 2. Bringing back the PT party owner, a convicted criminal. 3. Miscalculating the cost of the digital wallet. 4. Seizing large quantities of BB guns that were lawfully imported in order to keep chinese tourists safe from BB guns. 5. Giving visa free travel to Kazakh tourists. 6. Reviving the land bridge project for the Nth time. I could go on but....

I wonder if there are any Thais fighting for Hamas. There were definitely Thais with Isis.

Israeli citizens residing overseas are legally liable to military service in Israel, even if they have lived all their lives outside Israel with another citizenship. But in practice they can get deferment, if they don't go to live in Israel before they are 28 or so. Obviously they can't force a Thai-Israeli male living in Thailand who has to attend the draft board in Thailand to travel to Israel to be drafted there as well. But there are some who choose to go to Israel and join up. Also, of course, Thai-Israelis living in Israel have to do military service. So no doubt there are Thai-Israelis of both categories in the Israeli army. Can't imagine them recruiting Thai mercenaries or wanting anyone trained by the Thai military though.

I agree totally but I think it is inevitable that someone will bite the bullet in the not too distant future and let VAT revert to 10%. Other ways of funding the digital wallet will also impact the poor indirectly. Borrowing to fund it is not free and has an impact, particularly with govt debt already over 60% of GDP. Cutting other welfare schemes impacts those poor citizens who get cut, eg those turning 60 who are not going to get the old age allowance. Disingenuously allowing it to partially fund itself through incremental VAT receipts, assuming a 3x multiplier effect when a multiplier of less than 1 is more likely will also result in more govt debt to plug the shortfall. Basically it is bad project because there is no good way to fund it and it will generate a much lower multiplier effect than claimed by the government.

Not that important to the topic but I was trying to refute the traditional dual pricing justification that Thais deserve lower prices because the pay taxes that go towards maintenance of these venues. A Thai earning 15k a month, if he spends all of that, pays 12,600 a year in VAT. Most Thais don't pay income but do pay VAT. Foreign tourists don't pay Thai income tax but also pay VAT while in Thailand and some may pay more than the average Thai.

That is absolutely right but it is very easy to do, hard to avoid and is a very efficient way of increasing the tax take. The current 2 year waiver of the official VAT rate of 10% expires in September 2024. No legislation is required. Just do nothing and VAT is back to 10%, raising about 250 billion which would be enough to pay for a cut back digital wallet.

I thought that was exactly what the topic was about. The tax is aimed mainly at Thais and the PM said it is to improve equality.,

The work force is reported by the NESDB at 40 million but that includes legal foreign workers. An article from May 2023 in a source that I cannot link here about targets for tax reform quoted an RD source as saying around 11 million people filed tax returns, of whom around 4 million paid tax. That includes filings and tax paid via PND 90 and PND 91 tax return forms. PND 90 is for anyone who has income other than or in addition to income from employment subject to withholding tax, including sole proprietorships like your wife doing business in their personal name with no corporate or registered partnership structure. That means that most of the tax returns filed were from people who didn't have to pay tax because their income was too low (which may include a lot of sole proprietors whose deductions took them out of the tax net) and salaried employees seeing refunds of withholding tax.