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Investor Profile

Canadian Trust

2020

i | ER R OR ! N O TEXT OF SPEC IF IED STYLE IN D OC U M EN T.

Disclaimer

The information provided in this publication is for general information purposes only and is valid as at January 1, 2020. 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, nor 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 Services™ 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.

i i | ER R OR ! N O TEXT OF SPEC IF IED STYLE IN D OC U M EN T.

Contents

Overview of RBC Investor & Treasury Services’ withholding tax policies 3

Markets 7

Additional comments: 19

rbcits.com

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 -8 series 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.

Certification of Residency

In order to obtain Double Taxation Treaty benefits in a number of foreign markets, the Canadian 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 Canadian 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 Canadian 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. Detai ls 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.

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.

For those qualifying investment funds who obtain a German Status Certificate for application of relief at source, the above does not apply.

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.

Client Service Managers will provide clients with the required documentation at the time of account opening or investment 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 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 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 the 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

Country Dividends

standard

Dividends

treaty

Corporate

bonds

standard

Government

bonds standard

Interest

treaty

Notes

Argentina

(No Tax

Service)

7 15* 0/15.05 0 12.5* Interest: Interest derived by non-residents from Argentinean government and corporate bonds is exempt from withholding tax. A 15.05% rate applies to privately placed debt

instruments. * Where the standard withholding tax rate is lower than the treaty rate, the standard rate

will prevail.

Australia

(Relief at Source

Territory)

0/30

30% rate

for unfranked

dividends, 0% rate for

fully franked

dividends

15 0/10

0/10 10

Where the

standard withholding

tax rate is lower than

the treaty rate, the

standard rate will prevail.

Documentation required from client:

None required

Forms that RBC Investor & Treasury

Services may complete on behalf of client

and process/ action to be:

None required

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

(Reclaim

Territory)

27.5 15 (12.5) 0 0 10*

*Where the






1. Power of attorney

2. T1013 (Tax Office Consent)

3. Full beneficiary details provided in completed Tax Questionnaire

4. Shareholder percentage questionnaire

5. Annual supplementary tax reclaim questionnaire

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


Tax reclaim application including

shareholder percentage information where applicable

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

Submitted to agent bank in Austria

Bangladesh

(No Tax

Service)

20/30 15 20 20 15 Dividends: A rate of 20% applies to non-resident companies. (Normally funds are 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).

Belgium

(Reclaim

Territory)

15*/30

*15% rate

applies to certain

shares issued on

or after 1 January,

1994 and shares of

investment companies

(SICAV's, SICAF's

and OPCC's)

15 (15)

0*/30

* 0% rate

applies for interest paid to

non-residents on registered

bonds issued by Belgium

banks and on registered

corporate bonds.

0 10

Where the






Reclaim:


2. Tax Office Authority





Reclaim:

Tax reclaim application sent to

client’s tax office for certification of residency

A Form C is prepared and submitted

to the agent

Brazil

(No Tax

Service)

0 0 15 0 15

Dividends: Brazilian subsidiaries may also pay interest on net equity ("INE") to its shareholders. INE is subject to 15% withholding tax on the date it is paid or credited to

the recipient (25% if it is paid to an investor domiciled in a low tax jurisdiction). Interest: Where the standard rate is lower than the treaty rate the former will apply.

Canada 1

(Domestic

Exemption at

Source

Territory)

25 0 0

0 0

Chile

(No Tax

Service)

35 15 4/35 4 15 Dividends: 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. Interest: A rate of 4% applies to interest on publicly offered local or foreign currency f ixed

income bonds.

China

(No Tax

Service)

10 15*

10 0/10 10 Interest: Domestic exemption applies to interest income from bonds issued by departments under the State Council in charge of treasuries (i.e. the Ministry of Finance). For the period from 7 November 2018 to 6 November 2021, overseas

institutional investors are temporarily exempt from CIT and VAT for the coupon interest income received in the China bond market.

* Where the standard rate is lower than the treaty rate the former will apply.

Colombia

(No Tax

Service)

0/25 15 5 0/5 10*

*Where the standard

withholding tax rate is

lower than the treaty

rate, the

Dividends: 0% withholding tax rate applies to dividends paid out of taxed profits. If profits are untaxed, dividends are subject to a rate of 25%.

Effective 1 January 2019, an 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 Republic2

(Relief at Source

/ Reclaim

Territory)

35 15 35 35 10 Documentation required from client:





Declaration of Beneficial ownership

Certificate of residence

Denmark

(Reclaim

Territory)

27 15 (12) 0 0 10*

*Where the standard



rate, the standard rate

will prevail.






Services may complete on behalf of client and process/ action to be:

Tax reclaim application

Sent to client’s tax office for certification of residency

Submitted to agent bank in Denmark

Estonia

(Tax service

not applicable)

0 15* 0 0 10*

* Where the standard rate is lower than the treaty rate the former will apply

Finland 2

(Relief at

Source/ Reclaim

Territory )

30 15 0 0 10*

*Where the standard




will prevail.


Relief at Source:

Beneficial owner details

(one off requirement per Tax Questionnaire, information update

required should details change)

Reclaim:



3. Full beneficiary details provided in


Services may complete on behalf of client and process/ action to be:

Relief at Source:

Beneficial owner breakdown to be provided prior to each

dividend payment

Reclaim:



completed Tax Questionnaire Submitted to agent bank in Finland

France 1

(Relief at

Source/Reclaim

Territory)

28 15 0 0 10*

*Where the






Relief at Source:


2. RC59 (Tax Office Consent)


completed Tax Questionnaire

Reclaim:







Relief at Source:

Specific Annexe to be renewed annually

Reclaim:


incorporating specific attestation


Submitted to agent bank in France

Germany

(Reclaim

Territory/Relief

at Source)

26.375 15 (11.375) 0 0 10*

*Where the standard




will prevail.





4. Shareholder percentage questionnaire (reclaim only)

5. Status Certificate (relief at source)


Services may complete on behalf of client and process/action to be:

Relief at Source

• Status Certificate to be lodged with

agent in Germany

Reclaim

Tax reclaim application including shareholder percentage information

sent to client’s tax office for certification of residency

Submitted to agent bank in Germany

Greece

(Relief at Source

Territory)

5 15* 0/15 0/15 10*

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). * Where the standard rate is lower than the treaty rate the former will apply

Hong Kong

(No Tax

Service)

0 15* 0 0 10* Dividends: Red chip stocks (issued by a company based in the Chinese mainland that is

incorporated internationally and listed on the Hong Kong Stock Exchange) are subject to WHT at 10%

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

Hungary

(No Tax

Service)

0 15* 0 0 10* *Where the standard withholding tax rate is lower than the treaty rate, the standard rate

will prevail.

India

(No Tax

Service)

0 25* 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 withhold taxes and the same are to be discharged by the recipient as advance tax.

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

Indonesia

(Tax Service

upon request)

20 15 20 20* 10 In order to achieve treaty relief, specific forms have to be completed by the beneficial

owner. The treaty relief forms require endorsement by the tax authorities in the relevant entity’s own jurisdiction or a Certificate of Tax Residence can be provided.

*0% on foreign currency denominated Indonesian government bond (conventional/sharia based/sukuk) l isted on a foreign market.

Ireland

(Domestic

Exemption at

Source/ Reclaim

Territory)

25

0*

*Under the

DWT scheme residents of

treaty countries are

entitled to full exemption on

dividend withholding tax

20 0 10*

*Where the

standard rate is lower than

the treaty rate the

former will apply


1. Power of attorney to enable RBC

Investor & Treasury Services to complete the required forms (one off

requirement per Tax Questionnaire, renewable should details change)

2. Tax Office details and reference number (one off requirement per Tax

Questionnaire, information update required should details change)

3. Tax Office Authority to enable RBC Investor & Treasury Services to

request certifications of residency


and process/action to be:

Clients are initially assigned to a general account to which the

maximum withholding tax rate is assigned

Once the Certificate of residency has been received, and if there is a

Power of Attorney in place, RBC Investor & Treasury Services will

complete a DWT form on behalf of the client and re-assign the account

to the exempt 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

(Relief at Source

Territory)

25 15 0*/23

0**/23***

10 Documentation required from client:

Relief at Source & Reclaims:





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

Relief at Source & Reclaims:

A114 form 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

(Relief at Source

Territory)

26 15 0/26

0/12.5 10 Documentation required from client:

1. Notarized Power of attorney (2 if assets are going to be held

domestically and at Euroclear) to enable RBC Investor & Treasury

Services to complete the required forms (one off requirement per Tax

Questionnaire, renewable should details change)

2. If assets are going to be held domestically and at Euroclear) to

enable RBC Investor & Treasury Services to complete the required

forms (one off requirement per Tax Questionnaire, renewable should

details change)

3. Tax Office details and reference

number (one off requirement per Tax Questionnaire, information update

required if details change).

4. Tax Office Authority to enable RBC

Investor & Treasury Services to request residency (Details provided



Once the required information / documentation have been provided by the client RBC Investor &

Treasury Services will complete an annual certificate on the client’s

behalf to secure treaty relief at source in respect of equities.

After having received the required information / documentation from the client RBC Investor & Treasury

Services will complete a one off declaration (renewable should any

details change) on the client’s behalf to secure exemption at source in

respect of interest income

in the Tax Questionnaire)

Corporate Interest: 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 multi lateral trading facilities, bonds traded in EU/EEA regulated markets

and multi lateral trading facilities issued by non-l isted 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.

Government Interest: A full domestic exemption applies to "white list" holders of Italian Government bonds.

Japan

(Relief at

Source

Territory)

15.315

15 0*/15.315

0**/15.315





3. JGB Exempt Account Declaration



Application Form for Tax Exemption

*0% rate applies to corporate & municipal bonds if held on the Bank of Japan's book

entry system and the intermediary acts as a qualifying intermediary.

**0% rate applies to government bonds if held on the Bank of Japan's book entry system

and the intermediary acts as a qualifying intermediary

Lithuania

(Tax Service

not applicable)

15 15 10* 0 10**

*Interest paid to legal entities resident in EEA and DTA countries is exempt.

** Where the standard rate is lower than the treaty rate, the standard rate applies.

Luxembourg

(No Tax

Service)

15 15 0 0 10*

*Where the standard rate is lower than the treaty rate, the standard rate applies.

Malaysia 0 15* 0/15 0/15 15 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;

i i) 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

(No Tax

Service)

10 15* 4.9/10/40 0 10* Interest: 4.9% rate is applicable to publicly traded debt instruments issued by Mexican

entities, to the extent such instruments are registered in the National Securities Register (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.

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

Morocco

(No Tax

Service)

15 15 10 10 15* *Where the standard rate is lower than the treaty rate, the standard rate applies.

Netherlands

(Tax Service not

applicable)

15 15 0 0 10*

*Where the

standard rate is lower than


standard rate applies


None required




None required

New Zealand

(Relief at Source

Territory)

15*/30

*Applies to fully

imputed dividends

15 0/2*/15

*2% rate applies where

Approved Issuer Levy

has been applied for

0/2/15

10*

*Where the standard rate

is lower than the treaty


applies


None required



None required

Norway

(Relief at Source

Territory)

25 15 0 0 10

Where the standard rate

is lower than the treaty








Certificate of Residency

Form A2

applies 4. Beneficial Owner Declaration Application for approval sent to

the Norwegian Tax Authorities.

Pakistan

(No Tax

Service)

7.5/15*/20** n/a 10*/17.5** 10*/17.5** 25 Dividends: 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.

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 mill ion.

*Filer rate

**Non-fi ler rate

Investors should consult their tax advisors for further information before investing in

Pakistan.

Peru

(No Tax

Service)

5 15* 4.99/30 0 15* Dividends: 4.1% applies to dividends generated before 2015 fiscal year. The rate was 6.8% for distributions from profits earned in 2015 and 2016.

Interest: 4.99% applies to interest payments made to a non-resident unrelated party that satisfies certain requirements.

*Where the standard rate is lower than the treaty rate, the standard rate applies

Philippines

(No Tax

Service)

30 25 20/30 20/30 15 Dividends: The rate is reduced to 15% if the country of domicile of the recipient allows a

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

(Reclaim

Territory)

19 15 (4) 20 20 10 (10) Documentation required from client:







Certificate of residency

Portugal 3

(Reclaim

Territory)

25/35**

15 (10) 0*/25/35**

0*/25/35**









Sent to client’s tax office for

certification of residency

Submitted to agent bank in Portugal

Income breakdowns

*Entities resident in a jurisdiction with a double taxation treaty (DTT) or a tax exchange

of information agreement (TIEA) concluded with Portugal are eligible for domestic exemption.

**35% rate applies where beneficial ownership is not disclosed.

Russia

(Tax Service

not applicable)

15 15 15*/20 0** 10 Interest:

*A 15% rate applies to interest income on corporate bonds that:

- 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

(No Tax

Service)

0 15* 0/15 0/15 15 Interest: Bonds that qualify as "qualifying debt securities" are exempt from tax.

*Where the domestic withholding tax rate is lower than the treaty rate, the domestic rate

will prevail

Slovakia

(No Tax

Service)

0 15* 0 0 10* *Where the domestic withholding tax rate is lower than the treaty rate, the domestic rate

will prevail.

South Africa 2

(Relief at

Source/Reclaim

Territory)

20 15 0*/15 0 10** Documentation required from client:






Reduced Rate of Tax Declaration

*Domestic exemption available on certain types of distribution such as interest on listed

debt instruments and debt instruments owed by banks.

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

South Korea

(Relief at Source

Territory)

22 15 0*/15.4

*A 0% rate applies to

interest arising on foreign

currency denominated

bonds issued abroad.

0*/15.4

*An exemption from tax applies

to interest income arising from

Korean Treasury Bonds and

Monetary Stabilization

Bonds acquired prior to 12

November 2010.





4. Supporting documentation from an official source (i.e. CRA) that states

that the client is a Canadian Trust



Form 72/2 (Application for

Entitlement to reduced Tax Rate

on Domestic Sourced Income)

Spain

(Reclaim

Territory)

19 15 (4) 0*/19

*A domestic exemption is

available on interest from

qualifying corporate

bonds

0*/19

*0% rate applies to certain

Government Treasury stock.

Interest on public debt paid to non-

residents without a permanent

establishment in Spain is exempt

on provision of a certificate of

residence







Quick Refund Procedure:

Certification of Tax residency

requested from client’s tax office

annually

Income breakdowns

Standard Reclaim Procedure:

Certified Tax Reclaim form

Income breakdowns

Sri Lanka

(No Tax

Service)

14 15 5 0 15 Dividends & Interest: Where the domestic withholding tax rate is lower than the treaty

rate, the domestic rate will prevail.

Sweden 2

(Relief at

Source/ Reclaim

Territory)

30 15 0 0 10

When the

domestic withholding


Relief at Source & Reclaim:




Reclaim:



domestic rate will

prevail






Submitted to agent bank in Sweden

Switzerland

(Reclaim

Territory)

35*

*Effective 1st January 2011, Swiss

companies may pay all or part of their

dividends tax free under the capital

distribution principle.

15 (20) 35 35 10 (25) Documentation required from client:




4. Shareholder percentage questionnaire



Tax reclaim application incorporating shareholder percentage information

Sent to client’s tax office for

certification of residency

Submitted to Swiss Tax Authorities

annually

Taiwan

(No Tax

Service)

21 15 15 15 10 Interest: 15% on short term bil ls, 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.

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

(No Tax

Service)

10 10 15 0/15 10 Interest: Government bond interest is exempt from withholding tax in certain cases, eg . 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

(Tax Service

not applicable)

15 20* 0 0 15* *Where the domestic withholding tax rate is lower than the treaty rate, the domestic rate

will prevail.

UK 2

(Relief at Source

Territory)

0 15*

*Where the

domestic withholding tax

rate is lower than the treaty

rate, the

0*/20

*0% rate

applies to interest from

publicly quoted securities

0 10*

*Where the

domestic withholding


the treaty


None required




None required

domestic rate will prevail

rate, the domestic

rate will prevail

US

(Relief at Source

Territory)

30 15 0*/30

*0% rate

applies to

portfolio debt

securities and

government

interest

0*/30

*0% rate applies

to portfolio debt

securities and

government

interest


W8-BENE Form (renewable should details

change, per Tax Questionnaire)




It is not possible for RBC Investor & 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

(No Tax

Service)

0/34 15 34 0 10

Dividends: Dividends are exempt from withholding tax when they are paid out of profits 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 Canadian resident mutual fund trusts, pooled fund trusts and unit trusts are eligible to benefit from the treaty so l ong as they meet the conditions therein and provide the required documentation. If 100% percent of the rights in the mutual fund are held by Canadian residents, and if the relevant documentation has been prov ided, the entity can benefit from the simplified procedure.

2

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 te rritories. 3

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

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 .

http://gmi.rbcits.com/rt/gss.nsf/File+Attachments/AU+Residents/$FILE/Statutes%20and%20Refund%20Timeframes%20-%20AU%20Residents.pdf

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