Cash collateral is “money lent”

This operational statement outlines a change of view by the Commissioner and sets out the approach that the Commissioner will be taking after changing his view on whether cash collateral provided as part of security lending and derivative transactions is “money lent”. The Commissioner’s view now is that interest arising on cash collateral may therefore be subject to obligations to withhold resident withholding tax (RWT) or non-resident withholding tax (NRWT).