Australian Interest Withholding Tax - Reducing the cost of global borrowings

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
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