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 business 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 Hong Kong, RBC Investor Services Bank S.A. is a restricted license bank and is authorized to carry on certain banking business in Hong Kong 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. ® / ™ Trademarks of Royal Bank of Canada. Used under licence. 1 | ER R OR ! N O TEXT OF SPECIFIED STYLE IN DOCUMENT. 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. rbcits.com 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.