Investor Profile

Omnibus – Non-Treaty

FEBRUARY 2020

1 | INVEST O R P R O F IL E

Disclaimer

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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

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(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

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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

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Services licence number 295018. Details about the extent of our regulation by the Australian Securities and Investment Commis sion are available on request. RBC

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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.