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Some people may suggest that the key difference lies in the fact that withholding tax-exempt status merely involves denying a benefit, not imposing a cost.
This was realised in the form of company tax, withholding tax, dividends and mineral royalties.
In particular, when legislation concerning funded supplementary pension schemes was introduced in 1992, contributions to funded schemes were subjected to a 15 % withholding tax.
It might be argued that there really is no punitive intent in withholding tax-exempt status, but even if that were so, the consideration would not be decisive.
It has been said that we will have a withholding tax if the eurobond market can be accommodated.
Even in the transitional period, only two of the 15 countries have said that they will definitely retain a withholding tax.
A withholding tax will affect only personal taxpayers.
Some part of that should be regarded as withholding tax and as qualifying for relief.
Since there is no withholding tax on interest and dividends, there are no provisions for its recovery.
We have accordingly agreed to retain the old rule that neither country will impose a withholding tax on dividends flowing to the other country.
All they pay is a withholding tax, and normally the same withholding tax which our shareholders in their companies pay when they receive dividends.
Interest-paying unit trusts may escape the withholding tax because they can amalgamate with non-interest paying unit trusts.
Bringing these benefits into tax will involve withholding tax refunds while benefit is being paid to a claimant.
The current proposal relates to both the cap and to the underlying withholding tax.
That shows that it is not capital liberalisation but the very imposition of a withholding tax that leads to an outflow of tax avoidance funds.
