How do I determine the tax residency of the issuer (source country)?

It can be difficult to determine the tax residency of an organisation based on information that is publicly available. Rules for determining tax residency vary from country to country. It is, therefore, possible that an organisation is considered a tax resident in multiple countries. If this is the case, a tax treaty determines which country has which levying rights.

Furthermore, the tax residency determination is usually dependent on specific facts and circumstances. The Netherlands, for example, takes into consideration whether the company is incorporated under Dutch law, where important business decisions are made, where lies the decision-making authority, where statutory directors meet and work, and where the books are kept, amongst other things.