Investor Profile

UK Corporate

2021

Disclaimer

The information provided in this publication is for general information purposes only and is valid as at January 1, 2021. Any changes to legislation or treaties will be published via the RBC Investor & Treasury Services Tax Newsflash procedure and subsequent editions of this publication will be updated accordingly. The information in this publication should not be regarded as advice. RBC Investor & Treasury Services™ are not responsible for the accuracy of the information, or for any actions taken based on the information. We strongly recommend consultation with appropriate tax advisors. RBC Investor & Treasury Services™ is a global brand name and is part of Royal Bank of Canada. RBC Investor & Treasury Services is a specialist provider of asset servicing, custody, payments and treasury services for financial and other institutional investors worldwide. RBC Investor Servic es™ operates through two primary operating companies, RBC Investor Services Trust and RBC Investor Services Bank S.A., and their branches and affiliates. In the UK, RBC Investor Services Trust operates through a branch authorized by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority. The Dubai Branch of RBC Investor Services Trust is regulated by the Dubai Financial Services Authority. In Australia, RBC Investor Services Trust is authorized to carry on financial services by the Australian Securities and Investments Commission under the AFSL (Australian Financial Services Licence) number 295018. In Singapore, RBC Investor Services Trust Singapore Limited (RISTS) is licensed by the Monetary Authority of Singapore (MAS) as a Licensed Trust Company under the Trust Companies Act and was approved by the MAS to act as a trustee of collective investment schemes authorized under S 286 of the Securities and Futures Act (SFA). RISTS is also a Capital Markets Services Licence Holder issued by the MAS under the SFA in connection with its activit ies of acting as a custodian. In Kong, RBC Investor Services Bank S.A. is a restricted license bank and is authorized to carry on certain banking business in by the Hong Kong Monetary Authority. RBC Investor Services Trust Hong Kong Limited is regulated by the Mandatory Provident Fund Schemes Authority as an approved trustee.

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Contents

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

Markets viii

Additional comments: xxi

This document provides an outline of the relevant withholding taxes applicable to corporates resident in the United Kingdom, in respect of securities income from portfolio investments. This Investor Profile is intended for use by UK resident corporations and collective investment vehicles organized as corporations (e.g., OEIC’s investing in cross border securities only).

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 Tax Questionnaire and relevant documents inc luding self -certification form for regulatory reporting purposes , as provided in the account opening package must be completed providing full details of the beneficial owner of any income received for the account. Where a Tax Questionnaire is not completed the Bank will not supply any tax services for that account and full withholding tax rates will be applied. 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 market, current procedures provides for a weekly report to be produced detailing the new market. At this stage the bank will, as part of its client monitoring service, 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. (Please refer to the Taxation SLS for full details of clients’ responsibilities and the service that can be expected from RBC Investor & Treasury Services).

General Requirements

Power of Attorney As a part of the account opening package (Tax Questionnaire) the Bank requires the completion of a Power of Attorney from the beneficial owner (or where appropriate the Trustees of a fund). 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. Note that due to market conditions clients requiring relief at source or reclaim services on Italian securities (including Italian Government Bonds held in a depositary such as Euroclear) must provide the Bank with a further two Notarized Powers of Attorney. 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 responsibility to provide the necessary documents on request. The most important of these markets is the US where completion of a W-8series form is a necessity. In addition, in certain cases a client may not wish to provide RBC Investor & Treasury Services with a Power of Attorney. In such cases it may be arranged for clients to complete any additional specific documentation required themselves.

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Certification of Residency In order to obtain Double Taxation Treaty benefits in a number of foreign markets, the United Kingdom Tax Office is required to issue certificates of residence or certify tax reclaim forms. In order to facilitate the issuance of certificates of residence and the certification of tax reclaim forms, for each United Kingdom resident client the Bank will require the beneficial owner to provide to it a Tax Office Authority document. This document enables the Bank to liaise directly with the company’s tax office in order to obtain appropriate United Kingdom residence certifications for tax relief claims. Please note that without this document no tax service can be offered to clients.

Country Specific Requirements

US Form W8-BEN/E 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 pertains to collective investment vehicles investing in Austria, France, Germany and / or Switzerland only. Details as at the end of the previous tax year are to be provided for new accounts and on an annual basis thereafter. 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 Investment Vehicle is required in the form of an original Certificate of Residence. This rule is effective retroactively to January 1, 2008.

France The purpose of providing shareholder percentage information is to prove that 100% of the participants in the fund are resident in the same country as the fund itself. If this is not the case then the fund cannot benefit from the simplified procedure. The percentage of participants resident in the same country as the fund must be taken at the close of the accounting year preceding the dividend payment date. Please note that Australian investment funds were not mentioned in Statement of Practice 4 J-1-05 which extended the simplified procedure in 2005. Therefore the treaty eligibility of these funds is unclear and may be assessed by the French tax authorities on a case by case basis.

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, only 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 may claim treaty benefits without providing this additional information. However, treaty benefits are, in principle, only available to the unit holders when the mutual fund is organized as a trust. For non-resident funds organized as trusts that pay tax in their countries of residence, the percentage of beneficial ownership declaration should not be required because these entities are generally considered by their country of residence to be the beneficial owners of the income.

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. Note that the requirement for shareholder percentage information applies to Australian resident “trust estates” (i.e. trust estates as defined in division 6 of Part III of the Income Tax Assessment Act 1936, as amended) investing in Switzerland. Australian resident “public trading trusts” and “corporate unit trusts” are entirely entitled to a treaty based refund in Switzerland and are therefore not required to supply any unit holder distribution information. Client Service Managers will provide clients with the required documentation at the time of account opening or inves tment in a new market, and periodically when renewals are required.

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 c ross 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 inability 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 Euroclear but excludes ADR’s.

3. GLOBAL MINIMUM TAX RECLAIM THRESHOLD

A minimum reclaim value is set for all withholding tax reclaim territories. All reclaims with a value falling under the minimum threshold for that market 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. ITALIAN BONDS HELD IN EUROCLEAR

An exemption from withholding tax exists for Italian bonds for eligible investors. Operationally the process for exempting bonds for clients who bulk trade across accounts is not available if the bonds are held in the Euroclear depositary. These clients must hold their Italian Bonds in t he Domestic Market if they wish to achieve exemption. However, any beneficial owner that operates a segregated account on Milvus and trades separately for that account will be offered a relief at source service in Euroclear, if required, from the date of receipt of the appropriate tax documentation required to exempt the account from Italian withholding tax.

Markets

Corporate Dividends Dividends Government Interest Country bonds Notes standard treaty bonds standard treaty standard

Argentina 7 15 0/15.05 0 12 Interest: Interest derived by non-residents from Argentinean government and corporate (No Tax Service) bonds is exempt from withholding tax. A 15.05% rate applies to privately placed debt instruments.

Australia 1 30/0 15 0*/10 0*/10 10 Documentation required from client Forms that RBC Investor & Treasury (Relief at 30% rate for None required Services may complete on behalf of client Source) unfranked and process/ action to be: dividends, 0% None required rate for fully franked dividends Interest: *No withholding tax will be applied on the following qualifying debt: -debt compliant with the Section 128F of the Australian Income Tax Assessment Act 1936, -Australian Commonwealth Treasury Notes (since December 4, 2009) -Global bonds denominated in AUD (“Matildas”)

Austria 27.5 15 (12.5) 0 0 0 Documentation required from client Forms that RBC Investor & Treasury (Reclaim 1. Power of attorney Services may complete on behalf of client Territory) and process/ action to be: 2. Tax Office Authority Tax reclaim application 3. Full beneficiary details provided in completed Tax Questionnaire  Sent to client’s tax office for certification of residency.  Submitted to agent bank in Austria

Bangladesh 30/20 15 20 20 10/7.5 Dividends: A rate of 20% applies to non-resident companies. (Normally funds are (No Tax Service) classified as a company as per section 2(20)(bbb) of Income Tax Ordinance 1984). A rate of 30% applies to non-residents (other than companies).

Interest: Under UK treaty 7.5% rate applies to interest derived by financial institution or insurance company.

Belgium 30/15* 10 (20) 30/0* 0 10/0 Documentation required from client Forms that RBC Investor & Treasury (Reclaim *15% rate * 0% rate 1. Power of attorney Services may complete on behalf of client Territory) applies to applies for 2. Tax Office Authority and process/ action to be: certain shares interest paid to issued on or non-residents 3. Full beneficiary details provided in Tax reclaim application after on registered completed Tax Questionnaire  Sent to client’s tax office for 1 January, bonds issued certification of residency 1994 and by Belgium  shares of banks and on Submitted to agent bank in Belgium investment registered companies corporate (SICAV's, bonds. SICAF's and OPCC's)

Brazil 0 n/a 15 0 n/a Dividends: Brazilian subsidiaries may also pay interest on net equity ("INE") to its (Non-Treaty shareholders. INE is subject to 15% withholding tax on the date it is paid or credited to Territory) the recipient (25% if it is paid to an investor domiciled in a low tax jurisdiction).

Canada 1 25 15 0 0 10/0* Documentation required from client Forms that RBC Investor & Treasury (Relief at Source *Where the NR301 is required for non-Canadian Services may complete on behalf of client Territory) standard rate is residents except Client Pools. For Non- and process/ action to be: lower than the None required treaty rate, the Canadian Client Pools a Form A is standard rate required – and these documents are applies required to enable them to receive the treaty rates. Dividends: The statutory withholding tax rate on dividends is 35%, less a tax credit which Chile 35 15 4/5/35 4 10* varies according to the rate of corporate tax paid by the issuing company. (No Tax Service) Interest: A rate of 4% applies to interest on publicly offered local or foreign currency fixed income bonds. A rate of 5% applies if the interest is derived from bonds or securities that are regularly and substantially traded on a recognized securities market. *Activation of the Most Favoured Nation clause in the Protocol of the Double Taxation Treaty effective 1 January 2019.

China 10 10 10 0/10 10 Interest: Domestic exemption applies to interest income from bonds issued by (No Tax Service) departments under the State Council in charge of treasuries (i.e. the Ministry of Finance).

Colombia 0/25 n/a 5 0/5 n/a Dividends: 0% withholding tax rate applies to dividends paid out of taxed profits. If (Non-Treaty profits are untaxed, dividends are subject to a rate of 25%.Effective 1 January 2019, an Territory) additional 7.5% withholding tax will apply to dividends regardless of whether the dividends are paid out of profits that have been taxed.

Interest: Payments related to Government external debt (foreign debt issued by the Colombian Government), that are negotiated and paid in any currency other than Colombian pesos and made to a non-resident are exempt from withholding tax.

Czech Republic 35* 15 35* 35* 0 Documentation required from client Forms that RBC Investor & Treasury (Relief at Source 1. Power of attorney Services may complete on behalf of client / Reclaim and process/ action to be:

Territory) 2. Full beneficiary details provided in completed Tax Questionnaire  Declaration of Beneficial ownership

 Certificate of Residence

*A rate of 15% applies to dividends and interest paid to a beneficial ow ner tax resident in a country w ith w hich the Czech Republic has an exchange of information agreement or double taxation treaty and w hen the identity of the beneficial ow ner of the income is disclosed. Otherw ise, the rate is 35%.

Denmark 27 15 (12) 0 0 0 Documentation required from client Forms that RBC Investor & Treasury Services may complete on behalf of client (Reclaim 1. Power of attorney Territory) and process/ action to be: 2. Tax Office Authority Tax reclaim application 3. Full beneficiary details provided in completed Tax Questionnaire  Sent to client’s tax office for certification of residency  Submitted to agent bank in Denmark

Estonia 0 15* 0 0 10* *Where the standard rate is lower than the treaty rate the standard rate will apply. (No Tax Service)

Finland 1 35* 0 (30) 0 0 0 Documentation required from client Forms that RBC Investor & Treasury (Relief at Relief at Source: Services may complete on behalf of client Source/ Reclaim and process/ action to be: Territory ) Beneficial owner details (one off requirement per Tax Relief at Source: Questionnaire, information update Beneficial owner breakdown to be provided required should details change) prior to each dividend payment Reclaim: Reclaim: 1. Power of attorney Tax reclaim application 2. Tax Office Authority  Sent to client’s tax office for 3. Full beneficiary details provided in certification of residency completed Tax Questionnaire  Submitted to agent bank in Finland

*clients documented with an Investor Self Declaration will remain with a rate

of 30%

France 1 26.5 15 0 0 0 Documentation required from client Forms that RBC Investor & Treasury (Relief at Source Relief at Source: Services may complete on behalf of client / Reclaim and process/ action to be: Territory) 1. Power of attorney to enable RBC Investor & Treasury Services to Relief at Source: complete the required forms (one off  Certified form to be lodged with agent requirement per Tax Questionnaire, in France annually renewable should details change) Reclaim:

2. Tax Office details and reference Tax reclaim application number (one off requirement per Tax  Sent to client’s tax office for Questionnaire, information update certification of residency required should details change)  Submitted to agent bank in France 3. Tax Office Authority Reclaim: 1. Power of attorney 2. Tax Office Authority

3. Full beneficiary details provided in completed Tax Questionnaire

Germany 26.375 15 (11.375) 0 0 0 Documentation required from client Forms that RBC Investor & Treasury (Reclaim 1. Power of attorney Services may complete on behalf of client Territory) and process/action to be: 2. Tax Office Authority Tax reclaim application including 3. Full beneficiary details provided in shareholder percentage information completed Tax Questionnaire  sent to client’s tax office for certification of residency  Submitted to agent bank in Germany

Greece 5 n/a 15/0 15/0 0* *The beneficial owner must be subject to tax on the income in the UK to benefit from the (Relief at Source reduced treaty rate. Territory) Interest: A 0% rate applies to interest on Private Sector Involvement (PSI) bonds. From 1 January 2014, interest arising on Treasury Bills and Government bonds is exempted from taxation when earned by entities (with no PE in Greece).

Hong Kong 0 15/0 0 0 10/0 Dividends: Pursuant to the People’s Republic of (PRC) Corporate Income Tax Law (No Tax Service) (CIT Law) and the Regulations on the Implementation of the PRC CIT Law that took effect from January 1, 2008, non-resident institutional investors are subject to 10% dividend withholding tax on passive income derived from PRC China, including dividends on H- share and Red companies. Where the standard rate is lower than the treaty rate the standard rate will apply.

Hungary 0 15 0/30 0 0 Interest: Effective 1 January 2010 interest derived from certain corporate bonds is subject (No Tax Service) to 30% tax although DTT domiciled residents will continue to be exempt.

India 0 15* 20 20 15 Interest: Corporate and government bond interest, and interest on foreign currency loans, is subject to a statutory withholding tax rate of 20%. Typically, the Government does not (No Tax Service) withhold taxes and the same are to be discharged by the recipient as advance tax.

*Where the standard rate is low er than the treaty rate, the standard rate w ill apply.

Indonesia 20 15 20 20* 10 In order to get treaty relief specific forms have to be completed within very tight (Tax Service on *0% on foreign deadlines. The treaty relief Forms require endorsement by the tax authorities in the Request) currency relevant entity’s own jurisdiction or a Certificate of Tax Residence can be provided. denominated Indonesian The requirements for DTT relief are complicated and subject to interpretation. As a government bond general rule the beneficial owner must: (conventional/sha ria based/sukuk) • be resident of a treaty country listed on a foreign • provide the required documentation market • not be an agent, nominee, trustee or conduit

Ireland 25 0* 20 0 0 Documentation required from client Forms that RBC Investor & Treasury (Domestic Services may complete on behalf of client *Under the 1. Power of attorney to enable RBC Exemption at DWT scheme Investor & Treasury Services to and process/action to be: Source/ Reclaim residents of complete the required forms (one off  Clients are initially assigned to a Territory) treaty countries requirement per Tax Questionnaire, general account to which the are entitled to renewable should details change) maximum withholding tax rate is full exemption 2. Tax Office details and reference assigned on dividend number (one off requirement per  Once the Certificate of residency has withholding tax Tax Questionnaire, information been received, and if there is a Power update required should details of Attorney in place, RBC Investor & change) Treasury Services will complete a 3. Tax Office Authority to enable RBC DWT form on behalf of the client and Investor & Treasury Services to re-assign the account to the exempt request certifications of residency location

 If tax has been deducted during the time that the client was assigned to the taxable account then a retroactive reclaim is possible to obtain the difference between the maximum tax deducted and the treaty rate

Israel 1&3 25 15 (10) 0*/23 0**/23*** 15 Documentation required from client Forms that RBC Investor & Treasury (Relief at Source The entity must Relief at source and reclaims: Services may complete on behalf of client Territory) and process/action to be: be subject to 1. Power of attorney tax in the UK in Relief at source and reclaims: order to benefit 2. Tax Office Authority  A114 form from the treaty 3. Full beneficiary details provided in rate completed Tax Questionnaire  Certificate of residence

*The Israeli Income Tax Ordinance provides a tax exemption on interest on publicly traded bonds issued by an Israeli company and paid to a non-resident, subject to conditions. **A 0% rate applies on interest payments to foreign residents on government bonds issued on or after 8 May 2000 which are traded in Israel and have a redemption period of at least 13 months from their original issue [subject to certain conditions]. An exemption exists on interest payments on government bonds purchased in foreign currency. ***Non-resident investors are subject to a 23% withholding tax rate on interest from short term government bonds, interest from redemption of Makams and distributions from REITs.

Italy 1 26 1.2 26/0* 12.5/0** 10/0 Documentation required from client Forms that RBC Investor & Treasury (Relief at Source Applicable to 1. Notarized Power of attorney (2 if Services may complete on behalf of client Territory) qualifying EU assets are going to be held and process/action to be: or EEA resident domestically and at Euroclear) to  Once the required information / entities enable RBC Investor & Treasury documentation have been provided by Services to complete the required the client RBC Investor & Treasury forms (one off requirement per Tax Services will complete an annual Questionnaire, renewable should certificate on the client’s behalf to details change) secure treaty relief at source in respect 2. Tax Office details and reference of equities. number (one off requirement per  After having received the required Tax Questionnaire, information information / documentation from the update required if details change). client RBC Investor & Treasury 3. Tax Office Authority to enable RBC Services will complete a one off Investor & Treasury Services to declaration (renewable should any request residency (Details provided details change) on the client’s behalf to

in the Tax Questionnaire) secure exemption at source in respect of interest income

*A full domestic exemption applies to "white list" holders of bonds issued by Italian banks,companies whose shares are listed in EU/EEA regulated markets and multilateral trading facilities, bonds traded in EU/EEA regulated markets and multilateral trading facilities issued by non-listed companies, bonds issued by former Italian public entities converted into joint stock companies, bonds and similar securities which are not traded in regulated markets if held by one or more qualified investors in accordance with art. 100 of Legislative Decree No. 58/1998. ** A full domestic exemption applies to "white list" holders of Italian Government bonds.

Japan 15.315 10 15.315/0* 15.315/0* 10 Documentation required from client Forms that RBC Investor & Treasury Services may complete on behalf of client (Relief at Source *0% rate *0% rate applies Territory) applies to to government and process/action to be: corporate & bonds if held on None required municipal the Bank of bonds if held Japan's book entry on the Bank of system and the Japan's book intermediary acts entry system as a qualifying and the intermediary. intermediary acts as a qualifying intermediary.

Lithuania 15 15 0 0 10* Interest: Effective 01.01.10 interest paid to legal entities resident in EEA and (No Tax Service) DTA countries is exempt. *Where the standard rate is low er than the treaty rate the standard rate w ill apply.

Luxembourg 15 15 0 0 0 (Tax Service not applicable)

Malaysia 0 10 15/0 15/0 10 Interest: A 0% rate applies to: (No Tax Service) i) interest paid or credited to any company not resident in Malaysia (other than such interest accruing to a place of business in Malaysia of such a company) in respect of Islamic securities or debentures issued in RM (other than convertible loan stock) approved by the Securities Commission; ii) interest paid or credited to any person in respect of Sukuk originating in Malaysia

(other than convertible stock) issued in any currency other than RM and approved by the Securities Commission or the Labuan Financial Services Authority.

Where the standard withholding tax rate is lower than the treaty rate, the standard rate will prevail.

Mexico 10 0 40/10/4.9 0 15 Interest: 4.9% rate is applicable to publicly traded debt instruments issued by Mexican (Relief at Source entities, to the extent such instruments are registered in the National Securities Register Territory) (RNV by its Spanish acronym). If instruments are, un- registered in the RNV, withholding tax will be 10%. 40% rate applies to residents of black listed countries.

If the standard withholding tax rate is lower than the treaty rate, the standard rate will prevail.

Morocco 15 25 10 10 10 (No Tax Service)

Netherlands 15 10 (5) 0 0 0 Documentation required Forms that RBC Investor & Treasury (Reclaim from client Services may complete on behalf of client Territory) 1. Power of attorney and process/action to be: 2. Tax Office Authority  Certificate of residency -Obtained from clients tax office 3. Full beneficiary details provided in completed Tax Questionnaire  Submitted to agent bank in the Netherlands

New Zealand1 15*/30 15 15/2*/0 15/2/0 10 Documentation required Forms that RBC Investor & Treasury (Relief at Source *Applies to *2% rate Where the from client Services may complete on behalf of client and process/action to be: Territory) fully imputed applies where standard rate is None required dividends Approved lower than the None required Issuer Levy has treaty rate, the been applied standard rate for applies

Norway 1 25 15/0 (25)* 0 0 0 Documentation required Forms that RBC Investor & Treasury (Relief at Source *The Tax from client Services may complete on behalf of client Territory/Reclai Exemption *For The Exemption Model only: and process/action to be: m Territory) Model provides 1. Tax Office details and reference *For The Exemption Model only: a WHT exemption for number (one off requirement per First-time reclaims application with “corporate Tax Questionnaire, information accompanying Norwegian Attestation and shareholders” update required should details Certificate of Residency. Thereafter it should

resident in the change) be possible to assign the investor to a EU/EEA effective 2. Tax Office Authority segregated account and apply exemption at source on provision of an annual retroactively 3. Beneficial owner questionnaire from 01.01.04 attestation.

Pakistan 7.5/15*/20** 15 10*/17.5** 10*/17.5** 15 Dividends: 7.5% = dividends paid by companies engaged in power generation or by (No Tax Service) purchasers of privatized power companies and by companies engaged exclusively in mining operations other than petroleum. The withholding tax rate on dividends distributed by a collective investment scheme, REIT Scheme or a mutual fund is 10% if the dividend is up to PKR 2.5 million and 12.5% if the dividend exceeds PKR 2.5 million. *Filer rate **Non-filer rate

Peru 5 n/a 4.99/30 0 n/a Dividend: 4.1% applies to dividends generated before 2015 fiscal year. The rate was 6.8% (Non-Treaty for distributions from profits earned in 2015 and 2016. Territory) Interest: 4.99% applies to interest payments made to a non-resident unrelated party that satisfies certain requirements.

Philippines 30 25 20/30 20/30 15 Dividends: The rate is reduced to 15% if the country of domicile of the recipient allows a (No Tax Service) tax credit for taxes deemed payable in the Philippines equivalent to 15%. Due to the restrictive and unworkable time frames introduced in the market, reduction at source is currently unavailable. Interest: The withholding tax rate for interest on peso denominated bonds derived by non-resident investors is 20%.

Poland 19 10 20 20 5 (No Tax Service)

Portugal 2&3 25/35* 15 (10) 0*/25/35** 0*/25/35** 10 Documentation required Forms that RBC Investor & Treasury (Reclaim *35% rate **35% rate *entities resident from client Services may complete on behalf of client and process/action to be: Territory) applies where applies where in a jurisdiction 1. Power of attorney beneficial beneficial with a double 2. Tax Office Authority Tax reclaim application ownership is ownership is taxation treaty not disclosed not disclosed (DTT) or a tax 3. Full beneficiary details provided in  Sent to client’s tax office for exchange of

information completed Tax Questionnaire certification of residency agreement (TIEA) concluded with  Submitted to agent bank in Portugal Portugal are  Income breakdowns eligible for exemption. **35% rate applies where beneficial ownership is not disclosed

Russia 3 15 10 15*/20 0** 0 Interest: (Tax Service not *A 15% rate applies to interest income on corporate bonds that: applicable) - are issued by Russian companies; - are RUB denominated; - are marketable as at the date of recognition of the interest income; and - are issued between 1 January 2017 and 31 December 2021. **15% rate applies to certain types of state and municipal securities

Singapore 0 0 0/15 0/15 5 Interest: Bonds that qualify as "qualifying debt securities" are exempt from tax. (No Tax Service) Where the standard rate is lower than the treaty rate, the standard rate applies.

Slovakia 0 15 0 0 0 Where the standard rate is low er than the treaty rate, the standard rate (No Tax Service) applies.

South Africa 1 20 10 (10) 0*/15 0 0 *Domestic exemption available on certain types of distribution such as interest on listed (Relief at debt instruments and debt instruments owed by banks. Source/Reclaim Territory) South Korea 22 15 0*/15.4 0*/15.4 10 Documentation required from client: Forms that RBC Investor & Treasury Services may complete on behalf of client (Relief at Source *A 0% rate *An exemption 1. Power of attorney Territory) and process/action to be: applies to from tax applies to 2. Tax Office Authority interest arising interest income  Form 72/2 (Application for on foreign arising from 3. Full beneficiary details provided in Entitlement to reduced Tax Rate currency Korean Treasury completed Tax Questionnaire denominated Bonds and on Domestic Sourced Income)

bonds issued Monetary abroad. Stabilization Bonds acquired prior to 12 November 2010.

Spain 19 10 (9) 19/0* 19/0* 0 Documentation required Forms that RBC Investor & Treasury (Reclaim *A domestic *0% rate applies Interest paid to from client Services may complete on behalf of client and process/action to be: Territory) exemption is to certain an EU resident 1. Power of attorney available on Government without a 2. Tax Office Authority Quick Refund Procedure: interest from Treasury stock. permanent 3. Full beneficiary details provided in  Certification of Tax residency qualifying establishment requested from client’s tax office corporate in Spain is completed Tax Questionnaire annually bonds exempt on provision of a  Income breakdowns certificate of Standard Reclaim Procedure: residence  Certified Tax Reclaim form  Income breakdowns

Sri Lanka 14* 15 5* 0 10 * Effective April 1, 2018 (No Tax Service)

Sweden 1 30 5 (25) 0 0 0 Documentation required Forms that RBC Investor & Treasury (Relief at from client Services may complete on behalf of client and process/action to be: Source/ Reclaim Relief at Source & Reclaim: Territory) Reclaim: 1. Power of attorney Tax reclaim application 2. Tax Office Authority  3. Full beneficiary details provided in Sent to client’s tax office for certification of residency completed Tax Questionnaire  Submitted to agent bank in Sweden

Switzerland 35* 15 (20) 35 35 0 (35) Documentation required Forms that RBC Investor & Treasury from client Services may complete on behalf of client (Reclaim *Effective 1st Territory) January 2011, 1. Power of attorney and process/action to be: Swiss 2. Tax Office Authority Tax reclaim application incorporating companies shareholder percentage information may pay all or 3. Full beneficiary details provided in part of their completed Tax Questionnaire  Sent to client’s tax office for dividends tax certification of residency

free under the 4. Shareholder percentage questionnaire for mutual fund  Submitted to Swiss Tax Authorities capital annually distribution corporates principle.

Taiwan 21 10 15 15 10 Interest: 15% on short term bills, Government/Corporate bonds/ Financial Debentures, (No Tax Service) Securitization Products e.g. ABS, REITs and RAETs, and repos on all of these. 20% applies to other forms of interest.

Relief at Source: To qualify for tax relief at source, eligible investors should consult with their appointed local tax agent in Taiwan for details and required documentation.

Thailand 10 10 15 15/0 10 Interest: Government bond interest is exempt from withholding tax in certain cases, eg. (No Tax Service) interest on a government bond paid by the Thai government to a non-resident individual and non-resident company not carrying on business in Thailand. Interest on bonds issued by a non-financial government organisation and acquired on or after 13 October 2010 is not exempt and is subject to the 15% domestic withholding tax.

Turkey 15 20 0 0 15 Interest: 0% rate applies to Government securities. However the Earthquake Tax Scheme (Tax Service not effective 1 January 2000 applies a surcharge of between 4% and 19% depending on Applicable) maturity. 0% rate under treaty applies to interest derived by Government.

US 30 15 30/0* 30/0* 0 Documentation required Forms that RBC Investor & Treasury (Relief at Source from client Services may complete on behalf of client Territory) *0% rate *0% rate applies W8-BENE Form (renewable should details and process/action to be: applies to to government change, per Tax Questionnaire) portfolio debt interest  It is not possible for RBC Investor & securities Treasury Services to complete this document on behalf of the beneficial owner  Once the appropriate W8-BENE form has been received and validated, the client will receive all income going forward with the correct rate of withholding tax applied

Venezuela 0/34 10 34 34 5 Dividends: Dividends are exempt from withholding tax when they are paid out of profits (No Tax Service) which have been subjected to Income Tax. Payments exceeding taxable profits are subject to withholding tax at a rate of 34%. 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%.

1 Generally speaking, where possible, RBC Investor & Treasury Services will take the necessary action in order to obtain upfron t relief at source on income. These territories have a mixture of reclaim and relief at source opportunities. In addition where a timing issue necessitates full withholding on income, retroactive reclaims will be processed in the above territori es.

2 Relief at source in respect of Portuguese income is possible in theory but is currently not achievable in practice. This is d ue to a market issue that RBC Investor & Treasury Services will continue to monitor.

3 As a result of measures introduced in the UK Finance Bill 2009, UK resident corporate investors are no longer eligible to red uced withholding tax rates on dividends paid in the following markets: Israel, Portugal, Russia, and the Ukraine. This is due to the fact that DTTs between the UK and a number of markets contain a ‘subject to tax’ clause and therefore require that dividends be subject to tax in the UK. As the new legislation provides for an exemption from UK tax, such dividends will no longer be considered subject to UK tax, thereby ren dering relief-at-source or reclaims unavailable to UK investors in markets where there is a ‘subject to tax’ clause in the treaty. Corporate investors may continue to access the reduced rates of withholding tax in cases where the treaty has a subject to ta x clause by electing out of the exemption.

Additional comments:

Relief at Source Territories (Or unspecified territories) - Please note that where standard withholding tax rates are lower than the specified treaty rate that the standard rate will apply. Reclaim Territories - Statutes and refund timeframes: Statutes & Refund Timeframes Tax rates for other markets in which investment is possible through RBC Investor & Treasury Services are available on request.