23
Global Withholding Tax Investor Profile Italian Collective Investment Fund FEBRUARY 2020

Global Withholding Tax · For custody clients, the German Investment Tax Act Reform introduces an additional withholding tax relief opportunity via relief at source for qualifying

  • Upload
    others

  • View
    2

  • Download
    0

Embed Size (px)

Citation preview

Page 1: Global Withholding Tax · For custody clients, the German Investment Tax Act Reform introduces an additional withholding tax relief opportunity via relief at source for qualifying

Global Withholding Tax

Investor Profile

Italian Collective Investment

Fund

FEBRUARY 2020

Page 2: Global Withholding Tax · For custody clients, the German Investment Tax Act Reform introduces an additional withholding tax relief opportunity via relief at source for qualifying

Disclaimer

© Copyright Royal Bank of Canada 2019. RBC Investor & Treasury Services™ (RBC I&TS) is a global brand

name and is part of Royal Bank of Canada. RBC I&TS operates primarily through the following companies: Royal

Bank of Canada, RBC Investor Services Trust and RBC Investor Services Bank S.A., and their branches and

affiliates. In Luxembourg, RBC Investor Services Bank S.A. is authorized, supervised and regu lated by the

Commission de Surveillance du Secteur Financier (CSSF), and jointly supervised by the European Central Bank

(ECB). In the United Kingdom (UK), RBC I&TS operates through RBC Investor Services Trust, London Branch and

Royal Bank of Canada, London Branch, authorized and regulated by the Office of the Superintendent of Financial

Institutions of Canada. Authorized by the Prudential Regulation Authority. Subject to regulation by the Financial

Conduct Authority and limited regulation by the Prudential Regulation Authority. Details about the extent of our

regulation by the Prudential Regulation Authority are available on request. RBC I&TS UK also operates through

RBC Europe Limited, authorized by the Prudential Regulation Authority, and regulated by the Financial Conduct

Authority and the Prudential Regulation Authority. Additionally, RBC I&TS’ trustee and depositary services are

provided through RBC Investor Services Bank S.A., London Branch, authorized by the CSSF and ECB, and

subject to limited regulation by the Financial Conduct Authority and Prudential Regulation Authority. Details about

the extent of our regulation by the Financial Conduct Authority and the Prudential Regulation Authority are

available on request. RBC Investor Services Bank S.A. maintains a representative office supervised by the

Federal Reserve Bank of New York. RBC Investor Services Trust (Australian Branch) is licensed and regulated by

the Australian Securities and Investment Commission, Australian Financial Services licence numbe r 295018.

Details about the extent of our regulation by the Australian Securities and Investment Commission are available on

request. RBC Investor Services Trust Singapore Limited is licensed by the Monetary Authority of Singapore (MAS)

as a Licensed Trust Company under the Trust Companies Act and approved by MAS to act as a trustee of

collective investment schemes authorized under S286 of the Securities and Futures Act. RBC Investor Services

Trust Singapore Limited is also a Capital Markets Services Licence Holder issued by MAS under the Securities

and Futures Act in connection with its activities of acting as a custodian. RBC Offshore Fund Managers Limited is

regulated by the Guernsey Financial Services Commission in the conduct of investment business. Reg istered

company number 8494. RBC Fund Administration (CI) Limited is regulated by the Jersey Financial Services

Commission in the conduct of fund services and trust company business in Jersey. Registered company number

52624. RBC Investor Services Bank S.A. is a restricted license bank authorized by the Hong Kong Monetary

Authority to carry on certain banking business in Hong Kong. RBC Investor Services Trust Hong Kong Limited is

regulated by the Mandatory Provident Fund Schemes Authority as an approved trustee. Royal Bank of Canada,

Hong Kong Branch, is regulated by the Hong Kong Monetary Authority and the Securities and Futures

Commission.

® / ™ Trademarks of Royal Bank of Canada. Used under licence.

Page 3: Global Withholding Tax · For custody clients, the German Investment Tax Act Reform introduces an additional withholding tax relief opportunity via relief at source for qualifying

INVESTOR PROFILE 2

Contents

Overview of RBC Investor & Treasury Services’ withholding tax policies 4

Markets 9

Additional comments: 22

Page 4: Global Withholding Tax · For custody clients, the German Investment Tax Act Reform introduces an additional withholding tax relief opportunity via relief at source for qualifying

INVESTOR PROFILE 3

This document provides an outline of the relevant withholding taxes applicable to an Italian Collective Investment Fund, in respect of securities income

from portfolio investments.

Page 5: Global Withholding Tax · For custody clients, the German Investment Tax Act Reform introduces an additional withholding tax relief opportunity via relief at source for qualifying

INVESTOR PROFILE 4

Overview of RBC Investor & Treasury Services’ withholding tax policies

1. ACCOUNT OPENING / NEW PORTFOLIO INVESTMENT

Information / documentation required from the client

When a client opens a Global Custody account for the first time, the appropriate and relevant documents must be completed providing full details of the

beneficial owner of any income received for the account. When a client initially opens a global custody account a detailed list of investment markets is

requested. This list provides the necessary information for the Bank to complete tax documentation or request additional client documentation to ensure

the appropriate tax rate is obtained in each market.

If, at a later date, the client’s investment strategy requires the opening of a global custody account in a new marke t, the Bank will complete or request any

necessary tax documentation.

If no such advice or requested documentation is received the Bank will not accept any liability for any tax losses incurred. Furthermore, it is the

responsibility of the client to advise the Bank of any changes that may lead to a reclassification of client type for the beneficial owner of the account or

other details relating to their tax status, such as a change in Local Tax Office or Tax Identification Number. Any changes must be advised to the Bank

within 10 business days

General Requirements

Power of Attorney

As a part of the account opening process the Bank requires the completion of a Power of Attorney (POA) from the beneficial owner (or where

appropriates a legal representative). This POA enables the Bank to complete many of the required documents in-house without further recourse to the

client. Market specific requirements are detailed below and markets where the Bank can complete documentation on behalf of the beneficial owner where

a POA is held are clearly marked.

Page 6: Global Withholding Tax · For custody clients, the German Investment Tax Act Reform introduces an additional withholding tax relief opportunity via relief at source for qualifying

INVESTOR PROFILE 5

Certain markets or scenarios exist where it is not possible for the Bank to complete the required documentation on behalf of the beneficial owner, even

under POA, and in these cases it will be the client’s responsibil ity to provide the necessary documents on request. The most important of these markets is

the US where completion of a W-8BEN form is a necessity.

Certification of Residency

In order to obtain Double Taxation Treaty benefits in a number of foreign markets, the Italian Tax Authorities are required to issue certificates of residence

or certify tax reclaim forms. Upon request from the Bank the client undertakes to liaise with his tax authorities to obtain appropriate certificates of

residency or necessary certifications of tax reclaim forms and to return them back to the Bank as soon as received. Please note that without these

documents the Bank will not be able to provide the client with a tax service.

Country Specific Requirements

US Form W8-BEN

This document alleviates the charge to US backup tax on US source income payments and gross sale proceeds received by RBC Investor & Treasury

Services across all countries of investment. For corporates invested in US bonds, it also enables "portfolio interest" to be paid without deduction of US

Non Resident Withholding Tax.

Collective Investment Vehicle Shareholder Percentage Questionnaire

This requirement applies to beneficial owners that are collective investment vehicles organized as corporations. Please refer to the guidelines /

explanatory notes provided below for further information.

Austria

A new rule was implemented at the end of December 2008 whereby each tax reclaim filed in Austria by a Non-Austrian resident Investment Vehicle must

include an Attestation of Holding providing shareholder percentage information. Additional disclosure of investors holding 10 % or more in the Invest ment

Vehicle is required in the form of an original Certificate of Residence. This rule is effective retroactively to January 1, 2008.

Page 7: Global Withholding Tax · For custody clients, the German Investment Tax Act Reform introduces an additional withholding tax relief opportunity via relief at source for qualifying

INVESTOR PROFILE 6

Germany

A requirement in the form of a ‘statement of beneficial ownership’ was introduced in 2000, which provides the German Tax Authority with the percentage

of shareholders or unit holders that are resident in the country where the fund is resident. If, for example, a fund provides a statement of beneficial

ownership or an attestation stating that 98% of its shareholders are residents of the country where the fund is resident, onl y 98% of the tax reclaim will be

paid. If the percentage of ownership is 98.01%, the percentage refund would be rounded up to the next highest whole number (i.e., 99%).

NB: If the mutual fund is itself a corporation or is treated as a corporation for tax purposes, the mutual fund should genera lly be able to claim treaty

benefits without providing this additional information.

For custody clients, the German Investment Tax Act Reform introduces an additional withholding tax relief opportunity via rel ief at source for qualifying

investment funds as of January 1, 2018 for income payments with a pay date after December 31, 2017. Qualifying investment funds include UCITS and

AIF entities which will be able to benefit from a reduced withholding tax rate of 15% on German sourced dividends.

Norway

As from 1 January 2019, a new process will be applicable to beneficial owners, residents of a double taxation treaty country (entitled to DTT rate) or

foreign EEA entities qualifying for the tax exemption model (0%), receiving dividends from Norwegian equities through RBC IS Luxembourg. For the

purpose of obtaining this relief or exemption at source, a beneficial owner certificate (self certification) must be submitted as well as a Certificate of

Residence.

In addition, beneficial owners must apply for an approval letter (through form A2) for their impacted legal entities.

Poland

New requirements for relief at source are delayed till June 30th 2019. If the total amount of qualifying payments exceeds PLN 2M (ca. EUR 456K) in a tax year,

as a rule the Polish payer will be obliged to collect and pay WHT at domestic rates – at 19% for dividends and 20% for interest. WHT domestic exemptions

(EU directives) and DTT reliefs would be disregarded at this stage. This would apply to the amount in excess of PLN 2M. The application of this threshold is

postponed till June 30th 2019 provided that DTT between Poland and investors’ country of residence includes an exchange of information between tax

authorities clause.

Taking into consideration that the ordinances do not clarify due diligence requirements to apply relief at source, the Polish sub-custodian will not be offering

RAS from the beginning of 2019.

The Polish local agent is currently defining the tax reclaims process in electronic form

Page 8: Global Withholding Tax · For custody clients, the German Investment Tax Act Reform introduces an additional withholding tax relief opportunity via relief at source for qualifying

INVESTOR PROFILE 7

Switzerland

The percentage shareholding for the underlying holders comprising a mutual or investment fund is required on an annual basis and should be taken at

the end of the fund’s accounting year. Claims for refund are generally based on the proportion of shares beneficially owned by shareholders resident in

the country of domicile of the fund.

2. CROSS BORDER CUSTODY AND SETTLEMENT – TAX RECLAIMS

Restrictions are placed on providing a withholding tax reclaim or relief at source service on cross border holdings. A cross border security is any security

settled and held by an agent in a country not being the home country of location of that security. Due to inherent risks such as an inabili ty to process

cross border reclaims by the sub agent holding the security and substantial agent fees where cross border reclaims are available.

This policy is extended to equity investments held through Clearstream or Euroclear.

3. GLOBAL MINIMUM TAX RECLAIM THRESHOLDS

A minimum reclaim value is set for all withholding tax reclaim territories. All reclaims with a value falling under the minimum threshold of eur350.00 will not

be processed by RBC Investor & Treasury Services. Such claims will be deleted from any accruals reported to clients. This is due to the fact that it is

uneconomic, based on agent charges and internal processing costs for RBC Investor & Treasury Services to process reclaims under a certain value.

4. SECURITIES LENDING

This document provides an outline of the relevant withholding taxes applicable in respect of securities income from portfolio investments only and does

not intend to cover withholding taxes applicable in respect of manufactured incomes from lent securities.

No tax reclaim service can be offered on manufactured incomes.

Page 9: Global Withholding Tax · For custody clients, the German Investment Tax Act Reform introduces an additional withholding tax relief opportunity via relief at source for qualifying

INVESTOR PROFILE 8

Page 10: Global Withholding Tax · For custody clients, the German Investment Tax Act Reform introduces an additional withholding tax relief opportunity via relief at source for qualifying

INVESTOR PROFILE 9

Markets

Country Di v i dends

standard

Di v i dends

treaty

Corporate bonds

standard

Gov ernment

bonds

standard

Interest

treaty

Notes

Argentina 10 15 0/15.05/35 0 20 Dividend: If the dividend distribution exceeds the after tax accumulated taxable income of the payer a withholding of 35% may be imposed on the

income

Interest: Interest derived by non-residents from Argentinean government

and corporate bonds is exempt from withholding tax. A 15.05% rate

applies to interest (other than bond interest) derived by non-resident

financial institutions which conform to the Basle standards for banks.

Otherwise, the domestic rate of withholding tax on interest derived by

non-resident companies is 35%.

Australia

(Relief at

Source

Territory)

0/30*

*30% rate for unfranked dividends,

0% rate for fully franked dividends

15 0/10 0/10 10 Documentation required from client:

1. Power of attorney

2. Beneficial owner details (one off requirement per Tax Questionnaire, information update required

should details change)

Forms that RBC Investor & Treasury Services may complete on behalf of client and

process/action to be:

1. client’s tax office for certification of residency

Austria

(Reclaim

Territory)

27.5 15 0 0 10 Documentation required from client:

1. Power of attorney

2. Full beneficiary details provided in completed Tax

Questionnaire

Forms that RBC Investor & Treasury Services may complete on behalf of client and

process/action to be:

Tax reclaim application is

1. Declaration of widely – held foreign

Page 11: Global Withholding Tax · For custody clients, the German Investment Tax Act Reform introduces an additional withholding tax relief opportunity via relief at source for qualifying

INVESTOR PROFILE 10

Country Di v i dends

standard

Di v i dends

treaty

Corporate bonds

standard

Gov ernment

bonds

standard

Interest

treaty

Notes

investment funds

2. Ersuchen um Erg]anzung Form in case the bank is client’s transfert

agent

3. Sent to client’s tax office for certification

of residency

4. Submitted to agent bank in Austria

Bangladesh 20 15 37.5 37.5 10 Interest: Foreign investors are permitted to invest in corporate debentures

and 5 and 10 years Treasury Bonds. However, transactions of these

bonds in the secondary market are rare.

Belgium

(Reclaim

Territory)

30/15*

*15% rate applies to

shares of investment companies

(SICAV's, SICAF's and OPCC's)

15

30*

* most corporate bonds

are exempt

0

15/0 Documentation required from client:

3. Power of attorney

4. Beneficial owner details (one off requirement per Tax Questionnaire, information update required

should details change)

Forms that RBC Investor & Treasury Services may complete on behalf of client and

process/action to be:

Tax reclaim application is

1. Sent to client’s tax office for certification of

residency

2. A Form C is prepared and submitted to the

agent

Page 12: Global Withholding Tax · For custody clients, the German Investment Tax Act Reform introduces an additional withholding tax relief opportunity via relief at source for qualifying

INVESTOR PROFILE 11

Country Di v i dends

standard

Di v i dends

treaty

Corporate bonds

standard

Gov ernment

bonds

standard

Interest

treaty

Notes

Brazil

0/15*

*15% if dividend is qualif ied as

“interest on net equity” or “Interest over

capital”

15 15 0 15 Dividend: if the income derives from a profit that has been submitted to

corporate tax, the revenue will be announced as dividend (0% withholding

tax) whereas if the issuer does not pay the corporate tax, the income will

be announced as “Interest on net equity” or ” Interest over capital” and

15% withholding tax applies

Interest: Interest arising in a Contracting State and paid to the

Government of the other Contracting State, a political subdivision thereof

or any agency (including a financial institution) wholly owned by that

Government or political subdivision shall be exempt from tax.

Canada

(Relief at

Source

Territory)

25 15 0 0 10 Documentation required from client:

1. Form NR-301

Forms that RBC Investor & Treasury Services may complete on behalf of client and

process/action to be:

1. Form - A

Chile 35 n/a 4/35 4/35 n/a Dividend: The statutory withholding tax rate on dividends is 35%, less a

tax credit which varies according to the rate of corporate tax paid by the

issuing company.

China 0/10 10 10 10 10 Dividend: Chinese ‘H’ and ‘B’ shares are subject to WHT at 10%

Colombia

0/25 n/a 14 14 n/a Dividend: 0% withholding tax rate applies to dividends paid out of taxed

profits. If profits are untaxed, dividends are subject to a rate of 25%.

Czech Republic

(Relief at

Source

Territory)

35 15 35 35 0 Documentation required from client:

1. BO Declaration

2. Power of Attorney

3. Beneficial owner details (one off requirement per Tax Questionnaire, information update

Forms that RBC Investor & Treasury Services may complete on behalf of client and

process/action to be:

1. Client’s tax office for certification of residency

2. Disclosure of client per income payment to the

Page 13: Global Withholding Tax · For custody clients, the German Investment Tax Act Reform introduces an additional withholding tax relief opportunity via relief at source for qualifying

INVESTOR PROFILE 12

Country Di v i dends

standard

Di v i dends

treaty

Corporate bonds

standard

Gov ernment

bonds

standard

Interest

treaty

Notes

required should details

change)

agent

Denmark

(Reclaim

Territory)

22*

* decrease from 27% to 22% for corporate non resident investors effective date July 1, 2016 but not yet clear guidelines- 27% remain

applicable

15 0 0 10 Documentation required from

client:

1. Power of attorney

2. Full beneficiary details provided in completed Tax

Questionnaire

Forms that RBC Investor & Treasury Services may complete on behalf of client and process/action

to be:

Tax reclaim application is

3. Client’s tax office for certification of residency

4. Electronic filing of beneficial owner and holding details submitted

to agent bank in Denmark

Estonia 0 15 0 0 10

Egypt 10 n/a 0/20 0/20 n/a Interest: Withholding tax on Government bonds issued after July 1,2008

increase from 0% to 20%. 20% also applies on T-Bill which are issued

after May 5, 2008

Finland

(Relief at

Source

Territory)

30 15 0 0 15 Documentation required from client:

1. Power of attorney

2. Full beneficiary details provided in completed Tax

Questionnaire

Forms that RBC Investor &

Treasury Services may complete on

behalf of client and process/action

to be:

1. Client’s tax office for certification of residency

France

(Relief at

28

Dividends

0*

0% if the fund

0 0 0 Documentation required from

client: Forms that RBC Investor & Treasury Services may complete on

Page 14: Global Withholding Tax · For custody clients, the German Investment Tax Act Reform introduces an additional withholding tax relief opportunity via relief at source for qualifying

INVESTOR PROFILE 13

Country Di v i dends

standard

Di v i dends

treaty

Corporate bonds

standard

Gov ernment

bonds

standard

Interest

treaty

Notes

Source

Territory)

from SIIC are subject to

15%

qualif ies for the UCITS or

AIF status

1. Power of attorney

2. UCITS attestation (one off requirement per Tax Questionnaire, renewable should details change)

3. Certified RPPM form duly completed and yearly renewed for AIF fund

behalf of client and process/action

to be:

1. Certified RPPM form to be lodged with agent bank in France for UCITS/AIF

funds

Germany

(Relief at

Source

Territory)

26.375 15 0

26.375% applies

on German convertible bonds

0 0 Documentation required from client:

1. German declaration for the electronic filing procedure

2. Full beneficiary details provided in completed Tax Questionnaire

3. Status Certificate (Statusbescheinigung) per sub-fund

Greece

(Relief at

Source

Territory)

5

0*

0% if the fund qualif ies for the

UCITS or AIF status

0 0 n/a Dividends: Notarized and apostilled UCITS Attestation to be lodged with agent bank in Greece for UCITS funds

Hong Kong 0 n/a 0 0 n/a

Hungary 0 10 0*/30 0 0 Interest: effective 1 January 2010 interest derived from certain corporate bonds is subject to 30% tax although DTT country residents will continue

to be exempt

Page 15: Global Withholding Tax · For custody clients, the German Investment Tax Act Reform introduces an additional withholding tax relief opportunity via relief at source for qualifying

INVESTOR PROFILE 14

Country Di v i dends

standard

Di v i dends

treaty

Corporate bonds

standard

Gov ernment

bonds

standard

Interest

treaty

Notes

India 0 n/a 20/42 20 n/a Interest: 20% rate applies to interest from foreign currency loans,

corporate and government bonds. 42% rate applies to all other interest.

Indonesia

(Relief at

Source

Territory)

20 15 20 10 10 Documentation required from client:

1. DGT form

2. Full beneficiary details provided in completed Tax Questionnaire

Forms that RBC Investor & Treasury Services may complete on behalf of

client and process/ action to be:

1. Certified DGT form to be lodged with agent bank in

Indonesia

Ireland

(Reclaim

Territory)

25 0

Under the DWT scheme residents of

treaty countries are entitled to full exemption

on dividend w ithholding tax

20

0 0 Documentation required from client:

1. Power of Attorney

2. Certified V2 Composite Form duly completed

Forms that RBC Investor & Treasury Services may complete on behalf of

client and process/ action to be:

Tax Reclaim application is

1. Sent to client’s tax office for certification of residency

2. Submitted to agent bank in Ireland

Israel

(Relief at

Source

Territory)

25 15

24 0 / 24

*24% applies on short term

government bonds

10 Documentation required from client

1. Power of attorney

2. Full beneficiary details provided in completed

Tax Questionnaire

Forms that RBC Investor & Treasury Services may complete on behalf of

client and process/ action to be:

1. client’s tax office for certification of residency

2. Yearly 2042 Form

3. Yearly A114 form

Italy

(Relief at

26 0 26/0* 12.5/0* 0 Documentation required from client:

Forms that RBC Investor & Treasury Services may complete on behalf of

Page 16: Global Withholding Tax · For custody clients, the German Investment Tax Act Reform introduces an additional withholding tax relief opportunity via relief at source for qualifying

INVESTOR PROFILE 15

Country Di v i dends

standard

Di v i dends

treaty

Corporate bonds

standard

Gov ernment

bonds

standard

Interest

treaty

Notes

Source

Territory) *0% rate if client

provides a Self Certif ication

*0% rate

applies if client provides a Self Certif ication

1. Client’s Italian fiscal code

2. “Visura di evasione”

document

client and process/ action to be:

1. One-time reporting of the client’s TIN to withholding

agent

2. Letter for CGT purpose

Japan

(Relief at

Source

Territory)

15.315

15 15.315/0*

*0% rate applies to

corporate & municipal bonds if

held on the Bank of Japan's book entry system

15.315/0*

*0% rate

applies to government

bonds if held on the Bank of Japan's book entry system

10 Documentation required from client:

1. Power of attorney

2. Full beneficiary details provided in completed

Tax Questionnaire

Forms that RBC Investor & Treasury Services may complete on behalf of

client and process/ action to be:

1. Application Form for Tax Exemption on interest

payment

2. Client’s tax office for certification of residency

3. Investor list breakdown

Lithuania 15 15 10/0*

10/0*

10 Interest: interest paid to legal entities resident in EEA and DTA countries

is exempt

Luxembourg 15 15 0 0 10

Malaysia 25 n/a 15 15 15 Dividend: There is no dividend withholding tax. However, there is a 25%

tax charge on the gross dividends which is a deduction of Malaysian tax

credits.

Mexico 10 15 30/10/4.9 0 15 Interest: 10% paid on negotiable instruments, 4.9% on interest paid to banks, 30% rate applies to residents of the black list countries

Page 17: Global Withholding Tax · For custody clients, the German Investment Tax Act Reform introduces an additional withholding tax relief opportunity via relief at source for qualifying

INVESTOR PROFILE 16

Country Di v i dends

standard

Di v i dends

treaty

Corporate bonds

standard

Gov ernment

bonds

standard

Interest

treaty

Notes

Morocco 15 15 10 0 10

Netherlands

15 15 0 0 10

New Zealand

(Relief at

Source

Territory)

15*/30

*15% applies to dividends fully imputed

15 15/2*

*2% rate applies w here Approved Issuer Levy has

been applied for

15/2/0 0/10 Documentation required from client:

1. Power of attorney

2. Full beneficiary details provided in completed Tax

Questionnaire

Forms that RBC Investor &

Treasury Services may complete

on behalf of client and

process/action to be:

1. Client’s tax office for certification of residency

Norway

(Relief at

Source

Territory)

25/01

1 The Tax

Exemption Model provides a WHT exemption for

“corporate shareholders” resident in the EU/EEA

effective

01 0 0 0

1

1 For the Exemption Model or DTT country resident:

Dividend: The Tax Exemption Model provides a WHT exemption for “corporate shareholders” resident in the EU/EEA effective retroactively from 01.01.04

Documentation required from client:

As of 01.01.2019, the foreign shareholder must be documented with a COR (< 3 years), a self certification (beneficial owner certificate) and

either:

(i) an approved withholding tax refund application or;

(ii) an approval from the Norwegian tax authorities confirming the dividend recipient's entitlement to a reduced withholding tax rate

Page 18: Global Withholding Tax · For custody clients, the German Investment Tax Act Reform introduces an additional withholding tax relief opportunity via relief at source for qualifying

INVESTOR PROFILE 17

Country Di v i dends

standard

Di v i dends

treaty

Corporate bonds

standard

Gov ernment

bonds

standard

Interest

treaty

Notes

Pakistan 7.5/12.5/20 25 10 10 30 Dividend: 7.5% = dividends paid by companies engaged in power

generation or by purchasers of privatized power companies and by

companies engaged exclusively in mining operations other than

petroleum

Effective July 1, 2015: the withholding tax has been increased from 15%

to 17.5% and from 10% to 12.5% for filers.

Effective July 1, 2016: the withholding tax has been increased from 17.5%

to 20% for non-filers and remains at 7.5% for filers.

Peru

6.8 n/a 30 0 n/a Dividend: 4.1% applies to dividends generated before 2015 fiscal year

Philippines 30 n/a 30 20 n/a

Poland

19

0

20

20 0

Page 19: Global Withholding Tax · For custody clients, the German Investment Tax Act Reform introduces an additional withholding tax relief opportunity via relief at source for qualifying

INVESTOR PROFILE 18

Country Di v i dends

standard

Di v i dends

treaty

Corporate bonds

standard

Gov ernment

bonds

standard

Interest

treaty

Notes

Portugal

(Reclaim

Territory)

25 15 25/0*

*0% rate applies to most corporate bonds

0

15 Documentation required from client:

1. Power of Attorney

2. Full beneficiary details provided in completed Tax

Questionnaire

Forms that RBC Investor & Treasury Services may complete on behalf of client and

process/action to be:

Tax reclaim application is

1. Sent to client’s tax office for certification of residency

2. Statement for Funds Form

3. Submitted to agent bank in Portugal

4. Income/transaction breakdowns (monthly

and yearly reports)

Romania

5 n/a 16 0 n/a

Russia

15 10 15/20 0 10 Interest: 15% rate applies to certain types of state and municipal

securities

Singapore

0 10 15 15 12.5 Dividend: REIT distributions are subject to 17% tax or 10% for non-

residents without a permanent establishment in Singapore

Interest: in practice most interest payments are tax exempt

Slovak Republic

0 15 19 0 0

Slovenia 27.5 n/a n/a n/a n/a

Page 20: Global Withholding Tax · For custody clients, the German Investment Tax Act Reform introduces an additional withholding tax relief opportunity via relief at source for qualifying

INVESTOR PROFILE 19

Country Di v i dends

standard

Di v i dends

treaty

Corporate bonds

standard

Gov ernment

bonds

standard

Interest

treaty

Notes

South Africa 20 15 0 0 10

South Korea

(Relief at

Source

Territory)

22 15 15.4 15.4 10 Documentation required

from client:

1. 29-13 Form

2. Annex to 29-13 Form

Forms that RBC Investor & Treasury Services may complete on behalf of client and process/action

to be:

1. Submission of client’s forms to agent bank in South Korea (quarterly

renewal)

Spain

(Reclaim

Territory)

19% n/a*/1**

* SICAV/F part II and SICAV/F-

FIS are excluded from tax treaty benefits

**1% tax rate

applies if the SICAV qualif ies for the UCITS status

19%/0*

* Interest paid to an EU resident w ithout a permanent

establishment in Spain is exempt on provision of a certif icate of

residence

19%/0*

* Interest paid to an EU resident w ithout a permanent

establishment in Spain is exempt on provision of a

certif icate of residence

0

Documentation required from client

1. Power of attorney

2. Full beneficiary details provided in completed Tax

Questionnaire

Forms that RBC Investor & Treasury Services may complete on behalf of client and process/action

to be:

Tax Reclaim application is:

1. Sent to client’s tax office for certification of

residency

2. Submitted to agent bank in Spain

3. Reclaim summary report

Sri Lanka 10 15 10 0 10

Page 21: Global Withholding Tax · For custody clients, the German Investment Tax Act Reform introduces an additional withholding tax relief opportunity via relief at source for qualifying

INVESTOR PROFILE 20

Country Di v i dends

standard

Di v i dends

treaty

Corporate bonds

standard

Gov ernment

bonds

standard

Interest

treaty

Notes

Sweden

(Relief at source

Territory)

30 0*

*0% tax rate applies if the SICAV qualifies for the UCITS

status

0 0 0 Documentation required from

client:

1. Power of attorney

2. Full beneficiary details provided in completed Tax Questionnaire

3. UCITS attestation

Forms that RBC Investor & Treasury Services may complete on behalf of client and process/action

to be:

Relief process:

1. UCITS Attestation Submitted to agent bank in Sweden

Switzerland 35

15 35 35 12.5 Documentation required from client

1. Power of attorney

2. Full beneficiary details provided in completed Tax Questionnaire

3. Shareholder percentage questionnaire

Taiwan

21 n/a 15 15 n/a Dividend: 30% = payment to non resident individuals, 25% = payments to

non resident corporations, 20% = payments on investments approved by

the ROC government pursuant to the Statute for Investment by Foreign

Nationals or the Statute for Investment by Overseas Chinese

Interest: 15% = short term bills, Government/Corporate bonds/ Financial Debentures, Securitization Products e.g. ABS, REITs and RAETs, and repos on all of these. 20% applies to other forms of interest.

Thailand

10 10 15 15/0 10 As the nominee concept does not apply in the Thai market then only the holder of the safekeeping account at the agent is recognized as beneficial owner.

Page 22: Global Withholding Tax · For custody clients, the German Investment Tax Act Reform introduces an additional withholding tax relief opportunity via relief at source for qualifying

INVESTOR PROFILE 21

Country Di v i dends

standard

Di v i dends

treaty

Corporate bonds

standard

Gov ernment

bonds

standard

Interest

treaty

Notes

Turkey

15

15 0 0 15 Dividend: REIT distributions are tax exempt. Most foreign institutional

investors have been granted non resident investment fund status (NRIF)

and are eligible for gross payments

Interest: 0% rate applies to Government securities. However the

Earthquake Tax Scheme effective 1 January 2000 applies a surcharge of

between 4% and 19% depending on maturity.

UK 0 n/a 0/20 0 n/a Dividend: REIT distributions part constituted of Property Income

Distribution are subject to 20% tax.

Interest: interest from UK Eurobonds, Gilts and eligible Bulldog Bonds are free of tax. Non-publicly traded corporate bonds are withheld at 20%

US

(Relief at

Source

Territory)

30 n/a 30/0*

*0% rate applies to

portfolio debt securities and government

interest

30/0*

*0% rate

applies to portfolio debt securities and

government interest

n/a Documentation required from client

1. W8-BEN Form (renewable should details change, per Tax

Questionnaire)

Forms that RBC Investor & Treasury Services may complete on behalf of client and process/action to be:

1. 1042-s reporting to US IRS

Venezuela 34 10? 34 34 10 Interest: Withholding tax is imposed on 90% of the gross payment for

individuals (the effective rate is 30.6%). Interest paid to financial

institutions is set at a flat rate of 4.95%.

Page 23: Global Withholding Tax · For custody clients, the German Investment Tax Act Reform introduces an additional withholding tax relief opportunity via relief at source for qualifying

INVESTOR PROFILE 22

Additional comments:

Relief at Source Territories (Or unspecified territories) - Please note that where standard withholding tax rates are lower than the specified treaty rate then

the standard rate will apply.

Tax rates for other markets in which investment is possible through RBC Investor & Treasury Services are available on request .