N-2023-31: Extension of the Transition Period for the Single-Country Exception Under Section 903 of the Internal Revenue Code

Notice 2023-31 announces that when proposed regulations under section 903 (REG-112096-22) are finalized, the Treasury Department and the IRS intend to extend the transition period for the single-country exception?s documentation requirement from May 17, 2023 to 180 days after the date final regulations adopting the single-country exception are filed with the Federal Register. The single-country exception provides relief from the source-based attribution requirement under section 903 for foreign withholding taxes on royalties paid for the use of intellectual property within the withholding jurisdiction.

Notice 2023-31 will be in IRB 2023-16, dated 04/17/2023.

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