section 9 5/2004 Non-residents Tax Act

The following will be primarily liable for the taxes corresponding to income they have paid, or derived from assets they manage or for
which they are depositories:
• The payer of the earnings accrued not through a permanent establishment.
• The receiver or manager of assets or rights not attached to a permanent establishment.
In the case of a payer of earnings as well as of a receiver or manager of assets or rights belonging to residents in countries or territories considered as 'tax havens', Tax authorities may claim the tax directly from the surety, even though the principal may not have been declared in default.
However, jointly and severally liable only applies when withholding is not compulsory