- 1
- During the transitional period referred to in Article 10 of the Directive, where the Beneficial Owner is resident in the Republic of Croatia and the Paying Agent is resident in Curaçao, Curaçao shall levy a withholding tax on Interest Payments at a rate of 35%. During this period, Curaçao shall not be required to apply the provisions of Article 4. It shall, however, receive information from the Republic of Croatia in accordance with that Article.
- 2
- The Paying Agent shall levy the withholding tax in the manner as described in Article 11, paragraphs 2 and 3 of the Directive.
- 3
- The imposition of withholding tax by Curaçao shall not preclude the Republic of Croatia from taxing the income in accordance with its national law.
- 4
- During the transitional period, Curaçao may provide that an economic operator paying interest to, or securing interest for, an entity referred to in Article 4, paragraph 2, of the Directive, established in the Republic of Croatia shall be considered the Paying Agent in place of the entity and shall levy the withholding tax on that interest, unless the entity has formally agreed to its name, address and the total amount of interest paid to it or secured for it being communicated in accordance with the last subparagraph of that paragraph.
- 5
- At the end of the transitional period, Curaçao shall be required to apply the provisions of Article 4 and shall cease to apply the withholding tax and the revenue sharing provided for in Article 5 and Article 6. If, during the transitional period, Curaçao elects to apply the provisions of Article 4, it shall no longer apply the withholding tax and the revenue sharing provided for in Article 5 and Article 6.
