The Romania Ministry of Finance recently published Circular Nr. 674003, which clarifies the application of the interest withholding tax provisions of the 2005 tax treaty with Austria following the introduction by Austria of a 25% withholding tax on interest payments to non-resident natural persons. Under the 2005 Austria-Romania tax treaty, the withholding tax rate for interest is 3%, although several exemptions apply including that the rate will be 0% as long as Austria, under its national legislation, levies no withholding tax on interest paid to a Romanian resident. Because of the change in Austria's national legislation in regard to interest...