NRWT for dividends paid to companies: Administering the new holding period tests in Article 10 of the NZ/Australia DTA (and in agreements with other countries)
This Commissioner’s statement discusses the correct rate of non-resident withholding tax (or NRWT) that must be withheld from a dividend paid to a corporate payee under the holding period test changes for tax treaties following the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (or MLI).