Effective July 1, 2020, regular payments subject to withholding, and fulfilling tax treaty requirements, will be subject to paying the withholding taxes and filing for a refund, which is estimated to be a 6-month lag.
Exceptions would be approval by the tax administration, also a 6-month process, or assertion by the board of directors that all requirements have been met which is subject to personal liability and therefore a personal deterrent.
As other countries generally follow such trends, will COVID-19 prompt such actions to preserve final cash flow?
EY’s Alert provides additional details on this development.
Strategizing Multinational Tax Risks 
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