Extract to table

The Qualified Intermediary ("QI") status of Meridian Trust and the operational capabilities of the German sub-custodian are critical to determining whether reduced treaty-rate withholding can be applied at source (Freistellungsverfahren) or whether US holders must bear the full statutory rate and subsequently apply for refunds

The Company must determine and disclose the extent (if any) to which a given distribution is made from the steuerliches Einlagekonto

The LOB provision requires that, in order to claim treaty benefits, a resident of a Contracting State must satisfy one of several objective tests demonstrating a sufficient nexus to that State

375% is withheld, and the US holder must apply to the BZSt for a refund of the excess amount (11

In the absence of such documentation, the full statutory rate is withheld, and the beneficial owner must seek a refund from the BZSt under Section 50d(1) EStG

In this case, the US holder must apply to the BZSt for a refund of the excess withholding (i