Abstract

The WHT tax remitter is required to carry out due diligence when making payments subject to withholding tax. This obligation also applies in situations where the WHT tax remitter applies an exemption or reduced WHT rate. Previous administrative court case law has not addressed this issue comprehensively. However, in March 2025, the Supreme Administrative Court issued a landmark judgment in which it provided a thorough analysis of due diligence in withholding tax, particularly with regard to the obligation to verify the recipient of payment as the beneficial owner.