FAQ: Many companies pay interest quarterly. What amount of WTI must be withheld, 15% of the full amount paid in Mar for interest due in Jan, Feb and Mar or 15% of the Mar interest amount due, as WTI only became effective 1 March 2015?

WTI is triggered on the earlier of the date the interest is paid, or becomes due and payable. “Due and payable” is considered to be when there is a right to claim payment of the interest. Where it is contractually agreed that interest accrues on a quarterly basis and is paid at the end of that quarter the interest is only due and payable at the end of the quarter. As a result the entire interest accrued for the quarter ending March 2015 will be subject to WTI since the interest is due and payable after the effective date.