The guidelines defines "downloadable software for end-user" as a software downloaded by an end-user from the Internet or a network for a fee. They are sometimes referred to as "webwrap" or "clickwrap" software.
The end-user is a user who only acquires the right to run the software, not exploit the copyright to the program. Thus is a user downloads a software and then re-distributes the software, he is not considered as an end-user. Withholding tax will be payable in such a situation.