Investor Profile

Omnibus – Non-Treaty

2021

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, 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 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.

2 | 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 4

Markets 5

Additional comments: 12

This document provides an outline of the relevant standard withholding taxes applicable to undocumented omnibus accounts (i.e. financial institutions operating client pools on Milvus) and / or investors having signed a Tax Service Waiver and / or investors residing in territories that have no Double Taxation Agreements in place with other territories in respect of securities income from portfolio investments.

This Investor Profile is intended for use by clients investing in cross border securities that do not require or are not eligible for tax relief on global securities income 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 forms 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).

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.

Markets

Country Dividends

standard

Dividends

treaty

Corporate

bonds

standard

Government

bonds standard

Interest

treaty

Notes

Argentina 7

n/a 0/1 5.0535 0 n/a Inter est : Interest derived by non-r esidents from Argentinean government and corporate

bonds i s ex empt from w ithholding tax. A 15.05% r ate applies to privately placed debt

i nstruments.

Australia 0*/30

30% r ate for

unfr anked

di v i dends, 0%

r ate for fully

f r anked

di v i dends

n/a 0 0 n/a

Austria

27 .5 n/a 0 0 n/a

Bangladesh 20/30 n/a 20 20 n/a Di v idends: A r ate of 20% applies to non-resident companies. (N or mally funds are classified as

a company as per section 2(20)(bbb) of Income Tax Ordinance 1984). A r ate of 30% applies to

non-r esi dents (other than companies).

Belgium

1 5/30

n/a 30 0 n/a Di v idends: A 1 5% r ate applies to certain shares issued on or after

1 January, 1 994 and shares of investment companies (SICAV's, SICAF's and OPCC's).

Cor por ate Interest : A 0% r ate applies for interest paid to non -residents on registered bonds

i ssued by Belgium banks and on r egistered corporate bonds.

Brazil 0/25 n/a 1 5 0 n/a Di v idends: Br azilian subsidiaries may also pay interest on net equity ("IN E") to its

shar eholders. INE is subject to 15% w ithholdi ng tax on the date it is paid or credited to the

r ecipient (25% i f it is paid to an investor domi ciled i n a low tax jurisdiction).

Canada 25 n/a 0 0 n/a

Chile

35 n/a 4/35 4 n/a Di v idends: The statutory withholdi ng tax rate on dividends is 35%, l ess a tax credit w hich

v ar ies according to the r ate of corporate tax paid by the issuing company.

Inter est : A rate of 4% applies to i nterest on publicly offered local or foreign currency f ixed

i ncome bonds.

China 1 0 n/a 1 0 0/1 0 n/a Inter est : Domestic exemption applies to interest income from bonds issued by departments

under the State Council in charge of treasuries (i .e. the Mi nistry of Finance). For the period

f r om 7 N ovember 2018 to 6 N ovember 2021 , overseas institutional investors are temporarily

ex empt from CIT and VAT for the coupon interest income received in the China bond mar ket.

Colombia 0/25 n/a 5/25 0/5/25 n/a Di v idends: 0% w i thholding tax rate applies to dividends paid out of taxed profits. If profits are

untax ed, di vidends ar e subject to a rate of 25%.

Ef fective 1 January 201 9, an addi tional 7.5% w ithholdi ng tax will apply to dividends regardless

of w hether the dividends are paid out of profits that have been taxed.

Inter est: 25% w i thholdi ng tax rate applies to foreign investors domi ciled i n a tax haven.

Inter est, payments related to Government external debt (foreign debt issued by the Colombian

Gov er nment), that are negotiated and paid i n any currency other than Colombian pesos and

made to a non-r esi dent are exempt f rom withholding tax.

Croatia 1 0 n/a 0 0 n/a Di v idends & Interest: A rate of 20% (ex cept interest from bonds that are exempted) applies to

i nv estors based in non-cooperative tax jurisdictions (as def ined by EU ) and w here there is no tax treaty in place between such countries and the Republic of Cr oatia as from 1 January 2019.

Di v idend and interest paid to individuals resident from one of the countries of the EU list of

non-cooper ative tax jurisdictions remains subject to a 12 % W HT rate (except interest from bonds that are exempted).

Czech Republic 35 n/a 35 35 n/a A r ate of 35% applies to dividend and interest income when paid to:

i ) a beneficial owner resident in a country with which the Czech Republic does not have an

ex change of information agreement.

i i ) w hen the identity of the beneficial owner of the income is undisclosed.

Denmark 27 n/a 0 0 n/a

Estonia 0 n/a 0 0 n/a

Finland 35 n/a 0 0 n/a

France 26.5 n/a 0 0 n/a The w i thholding tax rate is 75% where income is paid in a non -cooperative state or territory.

Germany 26.37 5 n/a 0 0 n/a

Greece 5 n/a 0/1 5 0/1 5 n/a Inter est : A 0% r ate applies to interest on Private Sector Involvement (PSI) bonds. Fr om 1

Januar y 2014, i nterest arising on Treasury Bills and Gov ernment bonds i s exempted f rom

tax ation when earned by entities (w ith no PE i n Greece).

Hong Kong 0 n/a 0 0 n/a Di v idends: Red chip stocks (issued by a company based in the Chinese mainland that is

i ncorporated i nternationally and listed on the Hong Kong Stock Exchange) ar e subject to WHT

at 1 0%

Hungary 0 n/a 0 0 n/a

India 0 n/a 20 20 n/a Inter est: Cor porate and government bond interest, and i nterest on foreign currency loans, i s subject to a statutory withholdi ng tax rate of 20%. Ty pically, the Government does not

w i thhold taxes and the same are to be discharged by the recipient as advance tax.

Indonesia 20 n/a 20 20* n/a *0% on for eign currency denominated Indonesian government bond (conventional/sharia

based/suk uk) listed on a foreign market.

Ireland 25

n/a 20 0 n/a

Israel 25 n/a 0*/23 0**/23***

n/a *The Isr aeli Income Tax Ordinance provides a tax exemption on interest on publicly traded

bonds i ssued by an Israeli company and paid to a non-r esident, subject to condi tions.

**A 0% r ate applies on interest payments to foreign residents on government bonds i ssued on

or af ter 8 May 2000 w hich are traded in Israel and have a redemption period of at least 13

months f r om their original i ssue [subject to certain conditions]. An exemption exists on

i nterest payments on government bonds purchased in foreign currency.

**N on-r esident investors are subject to a 23% w ithholding tax rate on interest from short term

gov er nment bonds, i nterest from r edemption of Makams and di stributions from REITs

Italy 26 n/a 26 1 2.5 n/a

Japan 1 5.31 5

n/a 0*/1 5.31 5

*0% r ate

appl ies to

cor porate bonds

i f held on the

Bank of Japan's

book entry

0*/1 5.31 5

*0% r ate applies to

gov er nment bonds

i f held on the Bank

of Japan's book

entr y system and

the i ntermediary

n/a

sy stem and the

i ntermediary

acts as a

qual i fying

i ntermediary

acts as a qualifying

i ntermediary

Latvia 0 n/a 0 0 n/a The w i thholding tax rate on dividends and interest is 20% for all investors r esiding in a low-

tax or tax free jurisdiction.

1 0% w i thholding tax on dividends will still be applicable during 2018 and 201 9 to dividends

pai d by Latvian companies (from profits derived until the end y ear 2017) to non -resident

i ndi viduals. Afterwards 0% tax rate will be applicable to dividends paid b y Latvian companies

to non-r esident individuals provided that the company has paid corporate income tax from its

pr of its di stributed to shareholders.

Lithuania

1 5 n/a 1 0 0 n/a Inter est: Ef fective 01.01.1 0 interest paid to legal entities resident in EEA and DTA countries is

ex empt

Luxembourg 1 5 n/a 0 0 n/a

Malaysia 0 n/a 0/1 5 0/1 5 n/a Inter est : A 0% r ate applies to:

i ) i nterest paid or credited to any company not resident in Malaysia (other than such interest

accr uing to a place of business in Malaysia of such a company) in respect of Islamic securities

or debentures issued i n RM (other than convertible loan stock) approved by the Securities

Commi ssi on;

i i ) i nterest paid or credited to any person in respect of Sukuk originating in Malaysia (other

than convertible stock) i ssued in any currency other than RM and approved by the Securities

Commi ssi on or the Labuan Financial Services Authority.

Mexico 1 0 n/a 4.9/1 0/40 0 n/a Inter est: 4.9% r ate is applicable to publicly traded debt instruments issued by Mexican

enti ties, to the extent such instruments are registered in the N ational Securities Register (RNV

by i ts Spanish acronym). If instruments are, un- r egistered in the RNV, withholding tax will

be 1 0%. 40% r ate applies to residents of black listed countries.

Morocco 1 5 n/a 1 0 1 0 n/a

Netherlands

1 5 n/a 0 0 n/a

New Zealand 1 1 5*/30

*Applies to

ful ly imputed

di v i dends

n/a 0/2*/1 5

*2% r ate applies

w her e

Appr oved

Issuer Levy has

0/2*/1 5

n/a

been applied for

Norway

25 n/a 0 0 n/a

Oman

0 n/a 0 0 n/a Di v idends & Interest: 0% r ate effective 6 May 2019

Pakistan 7 .5/1 5*/20** n/a 1 0*/1 7.5** 1 0*/1 7.5** n/a Di v idends: 7 .5% = di vidends paid by companies engaged in power generation or by purchasers

of pr ivatized power companies and by companies engaged exclusively in mining operations

other than petroleum.

The w i thholding tax rate on dividends di stributed by a collective investment scheme, REIT

Scheme or a mutual fund is 1 0% i f the dividend is up to PKR 2.5 mi llion and 1 2.5% i f the

di v i dend exceeds PKR 2.5 mi llion.

*Fi ler rate

**N on-f iler rate

Inv estors should consult their tax advisors for further information before investing in

Pak i stan.

Peru 5 n/a 4.99/30 0 n/a

Inter est : A 4.99% w i thholding tax is applicable on interest received f rom corporate bonds, other debt instruments and deposits in the Peruvian f inancial system.

Effectiv e January 1, 2019, countries that are members of the OECD will not be considered tax hav ens.

Philippines 30 n/a 20/30 20/30 n/a Inter est: The withholdi ng tax rate for interest on peso denominated bonds derived by non-

r esi dent investors is 20%.

Poland

1 9 n/a 20 20 n/a

Portugal 25/35*

n/a 0**/25/35*

0**/25/35*

n/a *35% r ate applies w here beneficial ow nership is not di sclosed or resident for tax purposes in a

tax haven (black list jurisdiction)

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

i nformation agreement (TIEA) concluded with Portugal but on the black list are eligible for ex emption.

Russia 1 5 n/a 1 5*/20 0** n/a Inter est:

*A 1 5% r ate applies to interest income on corporate bonds that:

- ar e i ssued by Russian companies;

- ar e RU B denominated;

- ar e mar ketable as at the date of recognition of the interest income; and

- ar e i ssued between 1 January 2017 and 31 December 2021 .

**1 5% r ate applies to certain types of state and municipal securities

Singapore 0 n/a 0/1 5 0/1 5 n/a Inter est : Bonds that qualify as "qualifying debt securities" are exempt from tax.

Slovakia 0 n/a 0 0 n/a Di v idends : Investors domi ciled in non-treaty countries not included on the White Li st will be

subject to tax at a rate of 35%

South Africa 20 n/a 0*/1 5 0 n/a *Domesti c exemption available on certain types of di stribution such as interest on listed debt

i nstruments and debt instruments owed by banks.

South Korea

22 n/a 0/1 5.4 0/1 5.4 n/a Cor por ate Interest : A 0% r ate applies to i nterest arising on foreign currency denominated

bonds i ssued abroad.

Gov er nment Interest: An exemption from tax applies to interest income arising from Kor ean

Tr easury Bonds and Monetary Stabilization Bonds acquired prior to 1 2 November 2010.

Spain 1 9 n/a 0*/1 9

*A domesti c

ex emption is

av ai lable on

i nterest from

qual i fying

cor porate bonds

0*/1 9

*0% r ate applies to

cer tain

Gov er nment

Tr easury stock.

Inter est on public

debt paid to non-

r esi dents without a

per manent

establishment in

Spai n i s exempt on

pr ov ision of a

cer tificate of

r esi dence

0/1 9

Sri Lanka 1 4 n/a 5 0 n/a

Sweden 30 n/a 0 0 n/a

Switzerland 35*

*Ef fective 1st

Januar y 2011,

Sw i ss

compani es

may pay all or

par t of their

di v i dends tax

f r ee under the

capi tal

di str ibution

pr i nciple.

n/a 35 35 n/a

Taiwan

21 n/a 1 5 1 5 n/a Inter est: 1 5% on short term bills, Government/Corporate bonds/ Fi nancial Debentures,

Secur itization Products e.g. ABS, REITs and RAETs, and r epos on all of these. 20% applies to

other forms of interest.

Thailand 1 0 n/a 1 5 0/1 5

n/a Inter est : Government bond interest is exempt from w ithholdi ng tax in certain cases, eg,

i nterest on a government bond paid by the Thai government to a non-r esident individual and

non-r esi dent company not carrying on business in Thailand. Interest on bonds i ssued by a

non-f i nancial government organisation and acquired on or after 13 October 2010 is not

ex empt and i s subject to the 1 5% domestic withholding tax.

Turkey 1 5 n/a 0 0 n/a Inter est: 0% r ate applies to Government securities. However the Earthquake Tax Scheme

ef fective 1 January 2000 applies a surcharge of between 4% and 1 9% depending on maturity.

0% r ate under treaty applies to interest derived by Government.

UK 0

20% on U K

REITs

0/20 0*/20

*0% r ate

appl ies to

i nterest from

publicly quoted

secur ities

0 0/20

US 30 n/a 0*/30

*0% r ate

appl ies to

por tfolio debt

secur ities and

gov er nment

i nterest

0*/30

*0% r ate applies to

por tfolio debt

secur ities and

gov er nment

i nterest

0/30 Documentation required f rom client:

QI cl i ents can provide a W-8IMY form and

w i thholding statement to document their

pool ed accounts

For ms that RBC Investor & Treasury Services

may complete on behalf of client and

pr ocess/action to be:

It i s not possible for RBC Investor &

Tr easury Services to complete this

document on behalf of the beneficial

ow ner .

Once the appropriate W-8IMY for m has

been r eceived and validated, the client will

r eceive all income going forward with the

cor r ect rate of withholding tax applied

Venezuela 0/34 n/a 34 34 n/a Di v idends: Di vidends are exempt from withholding tax when they are paid out of profits which

hav e been subjected to Income Tax. Payments exceeding taxable profits are subject to

w i thholding tax at a rate of 34%.

Inter est: W ithholding tax is imposed on 90% of the gross payment for individuals (the

ef fective rate is 30.6%). Inter est paid to financial institutions is set at a flat rate of 4.95%.

Additional comments:

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