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Withholding Taxes in Latin America
The US rules are based on where those services performed but many I think non-US jurisdictions will just similar to royalty is well based with holding tax based on the pay who's making the payment. So that was a very big challenge for taxpayers particularly for those that had IP sitting in the US and they were attracting big royalty payments. The proposed regs that I think gave many of us a welcome change. They allow an alternative to satisfying the source base attribution through the so-called single country license.