A threshold question is whether taxation is to be on a net or gross basis. There are inevitable expenses associated with any type of service, so that taxation on a net basis is generally preferable2. If the tax is to be collected via withholding on the payer, then the “net” vs. “gross” issue could be addressed by treating the withholding tax as merely a collection mechanism. Overpayments of withheld tax should be refundable upon filing of a tax return with information proving the amount of net income. If a true gross basis tax is imposed, then the rate of withholding, as discussed further below, should be very low to reflect the likely existence of significant expenses. Again, ICC stresses the importance of arranging for double taxation relief in this respect as well.