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Investor Profile
Omnibus – Non-Treaty
FEBRUARY 2020
1 | INVEST O R P R O F IL E
Disclaimer
© Copyright Royal Bank of Canada 2019. RBC Investor & Treasury Services™ (RBC I&TS) is a global brand name and is part of Royal Bank of Canada. RBC I&TS
operates primarily through the following companies: Royal Bank of Canada, RBC Investor Services Trust and RBC Investor Servic es Bank S.A., and their branches
and affiliates. In Luxembourg, RBC Investor Services Bank S.A. is authorized, supervised and regulated by the Commission de S urveillance du Secteur Financier
(CSSF), and jointly supervised by the European Central Bank (ECB). In the United Kingdom (UK), RBC I&TS operates through RBC Investor Services Trust, London
Branch and Royal Bank of Canada, London Branch, authorized and regulated by the Office of the Superintendent of Financial Ins titutions of Canada. Authorized by
the Prudential Regulation Authority. Subject to regulation by the Financial Conduct Authority and limited regulation by the Prudential Regulation Authority. Det ails
about the extent of our regulation by the Prudential Regulation Authority are available on request. RBC I&TS UK also operates through RBC Europe Limited,
authorized by the Prudential Regulation Authority, and regulated by the Financial Conduct Authority and the Prudential Regulation Authority. Additionally, RBC I&TS’
trustee and depositary services are provided through RBC Investor Services Bank S.A., London Branch, authorized by the CSSF and ECB, and subject to limited
regulation by the Financial Conduct Authority and Prudential Regulation Authority. Details about the extent of our regulation by the Financial Conduct Authority and the
Prudential Regulation Authority are available on request. RBC Investor Services Bank S.A. maintains a representative office s upervised by the Federal Reserve Bank
of New York. RBC Investor Services Trust (Australian Branch) is licensed and regulated by the Australian Securities and Investment Commission, Australian Financial
Services licence number 295018. Details about the extent of our regulation by the Australian Securities and Investment Commis sion are available on request. RBC
Investor Services Trust Singapore Limited is licensed by the Monetary Authority of Singapore (MAS) as a Licensed Trust Company under the Trust Companies Act
and approved by MAS to act as a trustee of collective investment schemes authorized under S286 of the Securities and Futures Act. RBC Investor Services Trust
Singapore Limited is also a Capital Markets Services Licence Holder issued by MAS under the Securities and Futures Act in connection with its activities of acting as
a custodian. RBC Offshore Fund Managers Limited is regulated by the Guernsey Financial Services Commission in the conduct of investment business. Registered
company number 8494. RBC Fund Administration (CI) Limited is regulated by the Jersey Financial Services Commission in the conduct of fund services and trust
company business in Jersey. Registered company number 52624. RBC Investor Services Bank S.A. is a restricted license bank aut horized by the Hong Kong
Monetary Authority to carry on certain banking business in Hong Kong. RBC Investor Services Trust Hong Kong Limited is regulated by the Mandatory Provident Fund
Schemes Authority as an approved trustee. Royal Bank of Canada, Hong Kong Branch, is regulated by the Hong Kong Monetary Authority and the Securities and
Futures Commission.
® / ™ Trademarks of Royal Bank of Canada. Used under licence.
2 | INVEST O R P R O F IL E
Contents
Overview of RBC Investor & Treasury Services’ withholding tax policies 4
Markets 5
Additional comments: 13
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 elig ible 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, 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, curre nt 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. (Pl ease 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 with out deduction of US Non Resident
Withholding Tax.
Markets
Country Di v i dends
standard
Corporate bonds
standard
Gov ernment bonds
standard
Notes
Argentina 10 0/15.05/35 0 Dividends: If the dividend distribution exceeds the after tax accumulated taxable
income of the payer a withholding of 35% may be imposed on the income
Interest: Interest derived by non-residents from Argentinean government and
corporate bonds is exempt from withholding tax. A 15.05% rate applies to interest
(other than bond interest) derived by non-resident financial institutions which conform
to the Basle standards for banks. Otherwise, the domestic rate of withholding tax on
interest derived by non-resident companies
is 35%.
Australia 30/0*
30% rate for unfranked
dividends, 0% rate for fully franked dividends
0 0 Documentation
required from agent
Not applicable
Forms that RBC Investor & Treasury Services may complete
on behalf of client and process/ action to be:
Not applicable
Austria
(Reclaim
Territory)
27.5 0 0 Documentation
required from agent
Not applicable
Forms that RBC Investor & Treasury Services may complete on behalf of client and process/ action to be:
Not applicable
Bangladesh 20 37.5 37.5
Country Di v i dends
standard
Corporate bonds
standard
Gov ernment bonds
standard
Notes
Belgium
30/15*
*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)
30/0 0 Documentation
required from agent
Not applicable
Forms that RBC Investor & Treasury Services may complete
on behalf of client and process/ action to be:
Not applicable
Brazil 0 15 0
Canada 25 0 0 Documentation required from agent
Not applicable
Forms that RBC Investor & Treasury Services may complete on behalf of client and process/ action to be:
Not applicable
Chile
35 35/4 35/4 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.
China 0/10 10 10 Dividends: Chinese ‘H’ and ‘B’ shares are subject to WHT at 10%
Colombia 0/25 14/25 14/25 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%.
Interest: 25% withholding tax rate applies to foreign investors domiciled in a tax
haven.
Czech Republic 35 35 35
Country Di v i dends
standard
Corporate bonds
standard
Gov ernment bonds
standard
Notes
Denmark 22*
* decrease from 27% to 22% for corporate non resident investors effective date July 1, 2016 but not yet clear guidelines- 27% remain
applicable
0 0 Documentation required from agent
Not applicable
Forms that RBC Investor & Treasury Services may complete on behalf of client and process/ action to be:
Not applicable
Estonia 0 0 0
Finland 30 0 0 Documentation required
from agent
Not applicable
Forms that RBC Investor & Treasury Services may
complete on behalf of client and process/ action to be:
Not applicable
France 28 0 0 Documentation required
from agent
Not applicable
Forms that RBC Investor & Treasury Services may
complete on behalf of client and process/ action to be:
Not applicable
Germany 26.375 0 0 Documentation required from client
Not applicable
Forms that RBC Investor & Treasury Services may complete on behalf of client and process/action to be:
Not applicable
Greece 5 0 0
Hong Kong 0 0 0
Hungary 0 30/0 0
India 0 20/42 20 Interest: 20% rate applies to interest from foreign currency loans, corporate and
government bonds. 42% rate applies to all other interest.
Indonesia 20 20 20
Country Di v i dends
standard
Corporate bonds
standard
Gov ernment bonds
standard
Notes
Ireland 25
20 0 Documentation required from client
Not applicable
Forms that RBC Investor & Treasury Services may complete on behalf of client and process/action to be:
Not applicable
Israel 25 24 0 Documentation required
from client
Not applicable
Forms that RBC Investor & Treasury Services may complete on behalf of client and process/action to be:
Not applicable
Italy 26 26 12.5/0 Documentation
required from client
Not applicable
Forms that RBC Investor & Treasury Services may
complete on behalf of client and process/action to
be:
Not applicable
Japan 15.315
15.315 15.315/0*
*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
Documentation required
from client
Not applicable
Forms that RBC Investor & Treasury Services may
complete on behalf of client and process/action to be:
Not applicable
Lithuania
15 10 10 Interest: Effective 01.01.10 interest paid to legal entities resident in EEA and DTA
countries is exempt
Luxembourg 15 0 0
Malaysia 25 15 15 Dividends: There is no dividend withholding tax. However, there is a 25% tax charge
on the gross dividends which is a deduction of Malaysian tax credits.
Mexico 10 30/10/4.9 0 Interest: 10% paid on negotiable instruments, 4.9% on interest paid to banks, 30%
rate applies to residents of the black list countries
Morocco 15 10 10
Country Di v i dends
standard
Corporate bonds
standard
Gov ernment bonds
standard
Notes
Netherlands
15 0 0 Documentation required from client
Not applicable
Forms that RBC Investor & Treasury Services may complete on behalf of client and process/action to be:
Not applicable
New Zealand1 30 15/2*
*2% rate applies w here Approved Issuer Levy has been
applied for
15/2/0 Documentation required from client
Not applicable
Forms that RBC Investor & Treasury Services may complete on behalf of client and process/action to be:
Not applicable
Norway
25/01
1 The Tax Exemption Model
provides a WHT exemption for “corporate shareholders”
resident in the EU/EEA effective
0 0 1 For the Exemption Model or DTT country resident:
Dividend: The Tax Exemption Model provides a WHT exemption for “corporate
shareholders” resident in the EU/EEA effective retroactively from 01.01.04
Documentation required from client:
As of 01.01.2019, the foreign shareholder must be documented with a COR (< 3
years), a self certification (beneficial owner certificate) and either:
(i) an approved withholding tax refund application or;
(ii) an approval from the Norwegian tax authorities confirming the
dividend recipient's entitlement to a reduced withholding tax rate
Pakistan 7.5/10 10 10 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.
Peru 6.8 30 30
Philippines 30 30 30 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 17%. Due to
market practice dividends are paid at the appropriate treaty rate for the tax residence
of account holder (nominee). Therefore all dividends are paid at the UK treaty rate of
25%. Due to the restrictive and unworkable time frames introduced in the market,
reduction at source is currently unavailable.
Country Di v i dends
standard
Corporate bonds
standard
Gov ernment bonds
standard
Notes
Poland
19 20 20
The obligation to collect WHT at statutory rates is excluded for interest or discount on bonds issued by the State Treasury (on or after 2018.12.31) and offered on foreign
markets
Portugal 25 25/0*
*0% rate applies to
certain Treasury bonds
0
0% rate applies to all
government bonds
Documentation required from client
Not applicable
Forms that RBC Investor & Treasury Services may complete on behalf of client and process/action to be:
Not applicable
Russia 15 15/20 0 Interest: 15% rate applies to certain types of state and municipal securities
Singapore 0 15 15
Slovenia 27.5 0 0
Slovakia 0 19 0
South Africa 15 0 0
South Korea
22 22 22
Country Di v i dends
standard
Corporate bonds
standard
Gov ernment bonds
standard
Notes
Spain 20 20 20/0*
*0% rate applies to certain Government Treasury stock. Interest
on public debt paid to non- residents w ithout a permanent establishment in Spain is exempt on
provision of a certif icate of residence
Documentation required from client
Not applicable
Forms that RBC Investor & Treasury Services may complete on behalf of client and process/action to be:
Not applicable
Sri Lanka 10 10 0
Sweden 30 0 0 Documentation required
from client
Not applicable
Forms that RBC Investor & Treasury Services may
complete on behalf of client and process/action to be:
Not applicable
Switzerland 35
35 35 Documentation required
from client
Not applicable
Forms that RBC Investor & Treasury Services may
complete on behalf of client and process/action to be:
Not applicable
Taiwan
21 15 15 Dividends: 30% = payment to non resident individuals, 25% = payments to non
resident corporations, 20% = payments on investments approved by the ROC
government pursuant to the Statute for Investment by Foreign Nationals or the Statute
for Investment by Overseas Chinese
Interest: 15% = 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 10 15 15/0
Turkey 15 0 0 Interest: 0% rate applies to Government securities. However the Earthquake Tax
Scheme effective 1 January 2000 applies a surcharge of between 4% and 19%
depending on maturity. 0% rate under treaty applies to interest derived by
Government.
Country Di v i dends
standard
Corporate bonds
standard
Gov ernment bonds
standard
Notes
UK 0 20/0*
*0% rate applies to
interest from publicly
quoted securities
0 Documentation required from client
Not applicable
Forms that RBC Investor & Treasury Services may complete on behalf of client and process/action to be:
Not applicable
US 30 30/0*
*0% rate applies to
portfolio debt
securities and
government interest
30/0*
*0% rate applies to
portfolio debt securities
and government interest
Documentation required
from client
QI clients can provide a W-8IMY form and withholding statement to document their pooled
accounts
Forms that RBC Investor & Treasury Services may
complete on behalf of client and process/action to be:
It is not possible for RBC Investor & Treasury Services
to complete this document on behalf of the beneficial
owner.
Once the appropriate W-8IMY form has been received
and validated, the client will receive all income going
forward with the correct rate of withholding tax applied
Venezuela 34 34 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%.
Additional comments:
Tax rates for other markets in which investment is possible through RBC Investor & Treasury Services are available on request.