If an installment plan to pay a foreign business or manufacturer contains interest, the interest payment is subject to tax withholding by the domestic person charged with withholding duty when making payments.

　　　 Article 86, Paragraph 3, of the Income Tax Act, operative January 1, 1956, provided that a person receiving interest income shall be the taxpayer liable for that income. This tax liability is not limited to an individual. A business entity receiving interest income is taxable, too. As Article 85, Paragraph 1, of the same Act prescribed, a person charged with withholding duty is not exempted solely because the interest-receiving party is not an individual. Therefore, if an installment plan to pay a foreign business or manufacturer contains interest, the interest payment is subject to tax withholding by the domestic person charged with withholding duty when making payments.