Investor Profile Irish CorporateThis Investor Profile is intended for use by Irish resident corporations and collective investment vehicles organized as corporations (e.g., OEIC’s

Investor Profile

Irish Corporate

2020

1 | 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, 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 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.


Contents

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

Markets 8

Additional comments: 20

This document provides an outline of the relevant withholding taxes applicable to corporates resident in Ireland, in respect of securities income from portfolio investments.

This Investor Profile is intended for use by Irish 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 including 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 Irish 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 Irish 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 Irish 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.

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.

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 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

Country Dividends

standard

Dividends

treaty

Corporate

bonds

standard

Government

bonds standard

Interest

treaty

Notes

Argentina

(Non-treaty

Territory)

7 n/a 0/15.05 0 n/a Interest: Interest derived by non-residents from Argentinean government and corporate

bonds is exempt from w ithholding tax. A 15.05% rate applies to privately placed debt

instruments.

Australia

(Relief at Source

Territory)

0/30

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

Dividends: 30% rate for unfranked dividends, 0% rate for fully franked dividends.

Interest: No w ithholding tax w ill be applied on the follow ing qualifying debt:

- debt compliant w ith the Section 128F of the Australian Income Tax Assessment Act

1936

- Australian Commonw ealth Treasury Notes (since December 4, 2009)

- Global bonds denominated in AUD (“Matildas”).

Austria

(Reclaim

Territory)

27.5 10 (17.5) 0 0 0 Documentation required from client:

1. Power of attorney

2. Tax Office Authority

3. Full beneficiary details provided in completed Tax Questionnaire

4. Annual supplementary tax reclaim questionnaire

Forms that RBC Investor & Treasury 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 Austria

Bangladesh (Non-

treaty Territory)

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

classif ied 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 (15) 0/30 0 15* Documentation required from client:

Reclaim:

1. Pow er of attorney



Forms that RBC Investor & Treasury Services may

complete on behalf of client and process/ action to

be:

Reclaim:

Tax reclaim application sent to client’s tax

office for certification of residency

Submitted to agent bank in Belgium

Dividends: A 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).

Corporate Interest: A 0% rate applies for interest paid to non-residents on registered

bonds issued by Belgium banks and on registered corporate bonds.

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

Brazil

(Non-Treaty

Territory)

0 n/a 15 0 n/a Dividends: Brazilian subsidiaries may also pay interest on net equity ("INE") to its

shareholders. INE is subject to 15% w ithholding 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).

Canada 1

(Relief at Source

Territory)

25 15 0 0 10*

*Where the standard rate

is lower than the treaty

rate, the standard rate

applies


Relief at Source:

- NR301 is required for non-

Canadian residents except

Client Pools.

- For Non-Canadian Client

Pools a Form A is required.



action to be:

None required

Chile

(No Tax Service)

35 15 4/35 4 15 Dividends: The statutory w ithholding tax rate on dividends is 35%, less a tax credit

w hich varies according to the rate of corporate tax paid by the issuing company. Although relief may be available under treaty in theory, this is not obtained in practice.

Interest: A rate of 4% applies to interest on publicly offered local or foreign currency

f ixed income bonds.

China

(No Tax Service)

10 10 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.

Colombia

(Non-Treaty

Territory)

0/25 n/a 5 0/5 n/a Dividends: 0% w ithholding 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% w ithholding tax w ill apply to dividends

regardless of w hether 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 w ithholding tax.

Czech

Republic 1

(Relief at Source /

Reclaim Territory)

35* 15 35* 35*

0 Documentation required from client:


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:

Declaration of Beneficial ow nership

Certif icate 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

(Reclaim

Territory)

27 15 (12) 0 0 0 Documentation required from client:







action to be:

Tax reclaim application:

Sent to client’s tax off ice for certif ication of

residency

Submitted to agent bank in Denmark

Estonia

(Tax service not

applicable)

0 15* 0 0 10* *Where the standard rate is low er than the treaty rate, the standard rate w ill apply.

Finland 1

(Relief at Source/

Reclaim

Territory )

30 0 0 0 0 Documentation required from client:

Relief at Source:

Beneficial owner details (one off requirement per Tax Questionnaire, information update required should details change)

Reclaim:


Forms that RBC Investor & Treasury 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:


Sent to client’s tax office for certification of



residency

Submitted to agent bank in Finland

France 1

(Relief at

Source/Reclaim

Territory)


Relief at Source:

1. Pow er of attorney to enable RBC

Investor & Treasury Services to

complete the required forms (one off requirement per Tax

Questionnaire, renew able should

details change)

2. Tax Office details and reference

number (one off requirement per

Tax Questionnaire, information

update required should details

change)


Reclaim:







action to be:

Relief at Source:

Certif ied form to be lodged w ith agent in France annually

Reclaim:

Tax reclaim application incorporating

specif ic attestation


residency

Submitted to agent bank in France

Germany

(Reclaim

Territory)

26.375 15 (11.375) 0 0 0 Documentation required from client:






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


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 5* 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 w hen earned by entities (w ith no PE in Greece).

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

Hong Kong

(No Tax Service)

0 0 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%


Hungary

(No Tax Service)

0 15* 0 0 0 *Where the standard rate is low er than the treaty rate, the standard rate w ill apply.

India 0 10* 20 20 10 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.


Indonesia

(Non-Treaty

Territory)

20 n/a 20 20* n/a *0% on foreign currency denominated Indonesian government bond

(conventional/sharia based/sukuk) listed on a foreign market.

Ireland (Domestic

Exemption at

Source)

25

0

20 0 0 Documentation required from client:

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


may complete on behalf of client and

process/action to be:

Clients are initially assigned to a general account to w hich the maximum

w ithholding tax rate is assigned

Once the Certif icate of Residency has

been received, and if there is a Pow er of

Attorney in place, RBC Investor &

Treasury Services w ill 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 w as assigned to the taxable

account then a retroactive reclaim is

possible to obtain the difference betw een

the maximum tax deducted and the treaty

rate

Israel 1

(Relief at Source

Territory)

25 10 0*/23 0**/23*** 10 Documentation required from client:

Relief at Source & Reclaims:


2. Tax Office Consent






Relief at Source & Reclaims:

A114 form

Certif icate 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 certain conditions.

**According to the Income Tax Regulations, 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.

*** Withholding tax rate on interest from short term government bonds interest from redemption of Makams and distributions from REITs.

Italy 1

(Relief at Source

Territory)

26 1.2/15

Applicable to qualifying EU

or EEA resident

entities effective

0/26

A full domestic exemption

applies to "w hite list" holders of Italian corporate

bonds

0/12.5

A full domestic exemption applies to "w hite

list" holders of Italian Government bonds

10


1. Notarized Power of Attorney ( 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. Tax Office details and reference

number (one off requirement per Tax Questionnaire, information update

required if details change).

3. Client’s Self Certification

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

request residency




Once the required information /

documentation have been provided by the client RBC Investor & Treasury Services

w ill complete an annual certif icate 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 w ill

complete a one off declaration (renew able

should any details change) on the client’s

behalf to secure exemption at source in

respect of interest income

Japan

(Relief at Source

Territory)

15.315

15 0*/15.315

0**/15.315



2. Full beneficiary details provided in

completed Tax Questionnaire

3. JGB Exempt Account Declaration

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

be:

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

(No Tax Service)

15 15 0 0 10* Interest: Effective 01.01.10 interest paid to legal entities resident in EEA and DTA

countries is exempt.

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

Luxembourg

(Tax Service not

applicable)

15 15 0 0 0

Malaysia

(No Tax Service)

0 10* 0/15 0/15 10 Interest: A 0% rate applies to:

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 w ithholding tax rate is low er than the treaty rate, the standard rate

w ill prevail.

Mexico

(No Tax Service)

10 10 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,

w ithholding tax w ill be 10%. 40% rate applies to residents of black listed countries.

*If the standard w ithholding tax rate is low er than the treaty rate, the standard rate w ill

prevail.

Morocco

(Non-Treaty

Territory)

15 n/a 10 10 n/a

Netherlands

(Tax Service not

applicable)


None required




None required

New Zealand 1

(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

low er than

the treaty

rate, the

standard

rate applies


None required




None required

Norway 1

(Relief at

Source/Reclaim

Territory)

25 0 (25)*/15

*The Tax Exemption

Model provides a WHT

exemption for “corporate

shareholders” resident in the

EU/EEA effective

retroactively from 01.01.04

0 0 0 Documentation required from client:




4. Beneficial Owner Declaration


complete on behalf of client and process/action to

be:

Relief at Source & Exemption Model:

Certificate of Residency

Form A2

Application for approval sent to the

Norwegian Tax Authorities.

First-time reclaim application with

accompanying Norwegian Attestation and

Certificate of Residency. (Exemption model

only)

Pakistan

(No Tax Service)

7.5/15*/

20**

10 10*/17.5** 10*/17.5** 10 Dividends: 7.5% = dividends paid by companies engaged in pow er generation or by

purchasers of privatized pow er companies and by companies engaged exclusively in

mining operations other than petroleum.

The w ithholding 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-f iler rate

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

Peru

(Non-Treaty

Territory)

5 n/a 4.99/30 0 n/a Dividend: 4.1% applies to dividends generated before 2015 fiscal year. The rate w as 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 satisf ies certain requirements.

Philippines (Non-

Treaty Territory) 30 n/a 20/30 20/30 n/a Interest: The w ithholding tax rate for interest on peso denominated bonds derived by

non-resident investors is 20%.

Poland

(No Tax Service)

19 15 20 20 10

Portugal

(Reclaim

Territory)

25/35**

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

0*/25/35**








action to be:



residency

Submitted to agent bank in Portugal

Income breakdow ns

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

of information agreement (TIEA) concluded w ith Portugal are eligible for exemption.

**35% rate applies w here beneficial ow nership is not disclosed

Russia

(Tax Service not applicable)

15 10 15*/20 0** 0 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 betw een 1 January 2017 and 31 December 2021.

**15% rate applies to certain types of state and municipal securities

Singapore

(No Tax Service)

0 0 0/15 0/15 5 Interest: Bonds that qualify as "qualifying debt securities" are exempt from tax.

Where the standard rate is low er than the treaty rate, the standard rate applies.

Slovakia

(Tax Service not applicable)

0 10 0 0 0 Where the standard rate is low er than the treaty rate, the standard rate applies.

South Africa 1

(Relief at

Source/Reclaim

Territory)

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





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


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.

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.






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


Form 72/2 (Application for Entitlement to

reduce the 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

0

Interest paid

to an EU resident

without a permanent

establish-ment in

Spain is exempt on

provision of a certificate of

residence







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

Quick Refund Procedure:

Certif ication of Tax residency requested

from client’s tax off ice annually

Income breakdow ns

Standard Reclaim Procedure:

Certif ied Tax Reclaim form

Income breakdow ns

Sri Lanka

(Non-Treaty

Territory)

14* n/a 5* 0 n/a * Effective April 1, 2018

Sweden 1

(Relief at Source/

Reclaim Territory)


Relief at Source & Reclaim:






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

Reclaim:



residency

Submitted to agent bank in Sw eden

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 0 (35) Documentation required from client:





4. Shareholder percentage

questionnaire




Tax reclaim application incorporating

shareholder percentage information


residency

Submitted to Sw iss Tax Authorities

annually

Taiwan

(Non-treaty

territory)

21 n/a 15 15 n/a Interest: 15% on 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

(No Tax Service)

10 10 15 0/15 15 Interest: Government bond interest is exempt from w ithholding 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-f inancial government organisation and acquired on or after 13 October

2010 is not exempt and is subject to the 15% domestic w ithholding tax.

Turkey 15 10 0 0 15* Interest: 0% rate applies to Government securities. How ever the Earthquake Tax

Scheme effective 1 January 2000 applies a surcharge of betw een 4% and 19%

depending on maturity. 0% rate under treaty applies to interest derived by Government.

*Where the standard rate is low er than the treaty rate, the standard rate applies.

UK 1

(Relief at Source

Territory)

0

10 0*/20

*0% rate

applies to interest from

publicly quoted securities

0 0 Documentation required from client:

None required




None required

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 (renew able should

details change, per Tax

Questionnaire)




It is not possible for RBC Investor &

Treasury Services to complete this

document on behalf of the beneficial ow ner

Once the appropriate

W8-BENE form has been received and

validated, the client w ill receive all income

going forw ard with the correct rate of

w ithholding tax applied

Venezuela

(No Tax Service)

0/34 15 34 34 10 Dividends: Dividends are exempt from w ithholding tax w hen they are paid out of profits

w hich have been subjected to Income Tax. Payments exceeding taxable profits are

subject to w ithholding 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 f inancial institutions is set at a f lat rate of

4.95%.

1 Generally speaking, where possible, RBC Investor & Treasury Services will take the necessary action in order to obtain upfront relief at source on income. These territories may have a mixture of reclaim

and relief at source opportunities. In addition where a timing issue necessitates full withholding on income, retroactive rec laims will be processed in the above territories.

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.

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

For unspecified territories, RBC Investor & Treasury Services do not currently offer a tax service in these markets.

Documents

Investor Profile Irish CorporateThis Investor Profile is intended for use by Irish resident corporations and collective investment vehicles organized as corporations (e.g., OEIC’s