Lebanon: Procedure for relief at source on Lebanese Eurobond subject to Lebanese tax
Reference
Clearstream Banking1 informs customers that the interest payment distributed by the security with ISIN XS0969524064 is subject to 10% Lebanese withholding tax by default in Clearstream Banking Luxembourg (CBL).
Exemption at source is available for eligible beneficial owners according to the tax procedure below for this issue subject to Lebanese tax.
Who can obtain relief at source?
Exemption at source is available for beneficial owners that are a person or entity other than a bank, financial institution or trading entity subject to income tax in the Lebanese Republic pursuant to Chapter 1 of the Income Tax Code, and which are therefore eligible to claim a tax credit in the Lebanese Republic in respect of taxes required to be withheld by the issuer on payments of interest on such securities pursuant to Article 51 of Law No. 497 of the Lebanese Republic of 30 January 2003 (the “2003 Budget Law”) and related implementing regulations.
Quick refund or standard refund
Only relief at source is available through CBL. If no certification is received before the stated deadline, the standard withholding tax will be applied by default on the interest payment.
Documentation requirements and description
The documentation requirements are the same for all types of beneficial owners.
- One Time Certificate: Annex A
The certificate must be signed and completed by the CBL customer and remains valid until revoked. - Excluded Securities Notice: Annex B
This notice is to be provided per payment (when applicable) to exclude a payment from the previously provided One Time Certificate: Annex A in cases where beneficial owners are not eligible for the tax exemption initially requested via the One Time Certificate: Annex A.
Deadlines for receipt of documents
The documentation must be submitted on the record date minus one (1) business day of the relevant interest payment, by 10:00 CET. The exact deadline will be indicated in the dedicated field of the notification sent for each single payment. If no certification is received before the stated deadline, the standard withholding tax will be applied by default on the interest payment.
Where to send the documents
Documents must be sent in original and duly signed to the following address:
Clearstream Operations Prague s.r.o.
Attn: PTS - Tax Services Prague
Futurama Business Park Building B
Sokolovska 662/136b
CZ-18600 Prague 8
Czech Republic
Tax Forms to use
Please see the attachments below for the following forms:
- One Time Certificate: Annex A
- Excluded Securities Notice: Annex B
Important note
It is the customer's responsibility to ensure that final beneficial owners are eligible for the tax rates applied, including CBL default rates (currently 10%). Neither CBL nor its local depository has any direct or indirect liability towards the Lebanese authorities in this regard.
Further information
For further information, please contact the Clearstream Banking Tax Help Desk, Clearstream Banking Client Services or your Relationship Officer.
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1. Clearstream Banking refers collectively to Clearstream Banking S.A., registered office at 42, avenue John F. Kennedy, L-1855 Luxembourg, and registered with the Luxembourg Trade and Companies Register under number B-9248, and Clearstream Banking AG (for Clearstream Banking AG customers using Creation Accounts), registered office at 61, Mergenthalerallee, 65760 Eschborn, Germany, and registered in Register B of the Amtsgericht Frankfurt am Main, Germany, under number HRB 7500.ht Frankfurt am Main, Germany, under number HRB 7500.
