As a net capital importer, cheap and easy access to global debt is important for Australian businesses.  Australia makes available a wide array of exemptions from Australia’s 10% interest withholding tax.  Ensuring each transaction meets the letter and the spirit of the exemptions has a real 10% cash flow impact on Australian borrowers.  This guide describes the most commonly used exemptions in typical scenarios, including the public offer (“Section 128F”) exemption.

This article examines:

1. When is interest withholding tax payable?
2. Navigating the public offer exemption
3. Treaty exemptions
4. Other exemptions