Investor Profile Canadian Insurance Seg. Fund
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Investor Profile Canadian Insurance Seg. Fund 2022
Disclaimer The information provided in this publication is for general information purposes only and is valid as at January 1, 2022. 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 activities 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 | E R R O R ! N O T E X T O F S P E C I F I E D S T Y L E I N D O C U M E N T.
Contents Overview of RBC Investor & Treasury Services’ withholding tax policies i Markets v Additional comments: xvii ii | E R R O R ! N O T E X T O F S P E C I F I E D S T Y L E I N D O C U M E N T.
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 Clearstream) 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-8BEN 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-BENE 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 Clearstream 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 CLEARSTREAM 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 Clearstream 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 Clearstream, if required, from the date of receipt of the appropriate tax documentation required to exempt the account from Italian withholding tax.
Markets
Corporate
Dividends Dividends Government Interest
Country bonds Notes
standard treaty bonds standard treaty
standard
Argentina 7 15* 0/15.05 0 12.5* Interest: Interest derived by non-residents from Argentinean government and corporate
(No Tax bonds is exempt from withholding tax. A 15.05% rate applies to privately placed debt
Service) instruments.
* Where the standard withholding tax rate is lower than the treaty rate, the standard rate will
prevail.
Australia 0/30 15 0*/10 0*/10 10 Documentation required from client Forms that RBC Investor & Treasury Services
(Relief at Source 30% rate for Where the None required may complete on behalf of client and
Territory) unfranked standard process/ action to be:
dividends, withholding
0% rate for tax rate is None required
fully lower than
franked the treaty Interest: *No withholding tax will be applied on the following qualifying debt:
dividends rate, the -Debt compliant with the Section 128F of the Australian Income Tax Assessment Act 1936,
standard rate -Australian Commonwealth Treasury Notes (since December 4, 2009)
-Global bonds denominated in AUD (“Matildas”)
will prevail.
Austria 27.5 15 (12.5) 0 0 10* Documentation required from client Forms that RBC Investor & Treasury Services
(Reclaim 1. Power of attorney may complete on behalf of client and
*Where the
process/ action to be:
Territory) standard 2. Tax Office Authority
withholding Tax reclaim application including
tax rate is 3. Full beneficiary details provided in shareholder percentage information
lower than completed Tax Questionnaire
Sent to client’s tax office for
the treaty 4. Shareholder percentage certification of residency.
rate, the
standard rate 5. Annual supplementary tax reclaim Submitted to agent bank in
will prevail. questionnaire Austria
Bangladesh 20/30 15 20 20 15 Dividends: A rate of 20% applies to non-resident companies. (Normally funds are classified as
(No Tax a company as per section 2(20)(bbb) of Income Tax Ordinance 1984). A rate of 30% applies to
Service) non-residents (other than companies).Belgium 15*/30 15 (15) 0*/30 0 10 Documentation required from client Forms that RBC Investor & Treasury Services
(Reclaim *15% rate * 0% rate Where the Domestic Exemption at Source: may complete on behalf of client and
Territory) applies to applies for standard None required process/ action to be:
certain interest paid to withholding
shares non-residents tax rate is Reclaim: Reclaim:
issued on or on registered lower than Tax reclaim application
1. Power of attorney
after bonds issued by the treaty
1 January, Belgium banks rate, the 2. Tax Office Authority Sent to client’s tax office for
1994 and and on standard rate certification of residency
3. Full beneficiary details provided in
shares of registered will prevail. Submitted to agent bank in
completed Tax Questionnaire
investment corporate Belgium
companies bonds.
(SICAV's,
SICAF's and
OPCC's)
Dividends: Brazilian subsidiaries may also pay interest on net equity ("INE") to its
Brazil 0 0 15 0 15
shareholders. INE is subject to 15% withholding tax on the date it is paid or credited to the
(No Tax recipient (25% if it is paid to an investor domiciled in a low tax jurisdiction).
Service) Interest: Where the standard rate is lower than the treaty rate the former will apply.
Canada 1 25 0 0 0 0
(Domestic
Exemption at
Source Territory)
Chile 35 15 4/35 4 15 Dividends: The statutory withholding tax rate on dividends is 35%, less a tax credit which
(No Tax varies according to the rate of corporate tax paid by the issuing company.
Service) Interest: A rate of 4% applies to interest on publicly offered local or foreign currency fixed
income bonds.
Interest: Domestic exemption applies to interest income from bonds issued by departments
China 10 15* 10 0/10 10
under the State Council in charge of treasuries (i.e. the Ministry of Finance). For the period
(No Tax from 7 November 2018 to 6 November 2022, overseas institutional investors are temporarily
Service) 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.
Dividends: 0% withholding tax rate applies to dividends paid out of taxed profits. If profits are
Colombia 0/25 15 5 0/5 10*
untaxed, dividends are subject to a rate of 25%.
(No Tax *Where the Effective 1 January 2019, an additional 7.5% withholding tax will apply to dividends regardless
Service) standard of whether the dividends are paid out of profits that have been taxed.
withholding
tax rate is Interest: Payments related to Government external debt (foreign debt issued by the
lower than Colombian Government), that are negotiated and paid in any currency other than Colombian
the treaty pesos and made to a non-resident are exempt from withholding tax.
rate, the
standard rate
will prevail.Czech Republic 35* 15 0 35* 10 Documentation required from client: Forms that RBC Investor & Treasury Services
(Relief at Source may complete on behalf of client and
1. Power of attorney
/ Reclaim process/ action to be:
2. Tax Office Authority
Territory) Declaration of Beneficial ownership
3. Full beneficiary details provided in
completed Tax Questionnaire Certificate of residence
*A rate of 15% applies to dividends and interest paid to a beneficial owner tax
resident in a country with which the Czech Republic has an exchange of
information agreement or double taxation treaty and when the identity of the
beneficial owner of the income is disclosed. Otherwise, the rate is 35%.
Denmark 27 15 (12) 0 0 10* Documentation required from client: Forms that RBC Investor & Treasury Services
(Reclaim may complete on behalf of client and
*Where the 4. Power of attorney
process/ action to be:
Territory) standard
5. Tax Office Authority
withholding Tax reclaim application
tax rate is 6. Full beneficiary details provided in
Sent to client’s tax office for
lower than completed Tax Questionnaire
certification of residency
the treaty
rate, the Submitted to agent bank in
standard rate Denmark
will prevail.
Estonia 0 15* 0 0 10* * Where the standard rate is lower than the treaty rate the former will apply
Finland 1 35 15 0 0 10* Documentation required from client: Forms that RBC Investor & Treasury Services
(Relief at may complete on behalf of client and
*Where the Relief at Source:
process/ action to be:
Source/ Reclaim standard
Territory ) withholding
Investor Self Declaration Relief at Source:
tax rate is Reclaim: Beneficial owner breakdown to be provided
lower than
1. Power of attorney prior to each dividend payment
the treaty
rate, the 2. Tax Office Authority
standard rate
3. Full beneficiary details provided in Reclaim:
will prevail.
completed Tax Questionnaire
Tax reclaim application
4. Investor Self Declaration
Sent to client’s tax office for
5. Tax at Source Card (TASC) for exempt certification of residency
clients
Submitted to agent bank in
*clients documented with an Investor Self Finland
Declaration will remain with a rate of 30*France 1 25 15 0 0 10* Documentation required from client Forms that RBC Investor & Treasury Services
(Relief at Source may complete on behalf of client and
*Where the Reclaim:
process/ action to be:
/ Reclaim standard
1. Power of attorney
Territory) withholding Reclaim:
tax rate is 2. AUT 01 (Tax Office Consent)
Tax reclaim application
lower than 3. Full beneficiary details provided in
the treaty completed Tax Questionnaire Sent to client’s tax office for
rate, the certification of residency
standard rate Submitted to agent bank in France
will prevail.
Relief at Source:
1. Power of attorney
Relief at Source:
2. AUT 01 (Tax Office Consent)
Certified form to be lodged
3. Full beneficiary details provided in annually
completed Tax Questionnaire
Germany 26.375 15 (11.375) 0 0 10* Documentation required from client Forms that RBC Investor & Treasury Services
(Reclaim may complete on behalf of client and
*Where the 1. Power of attorney
process/action to be:
Territory) standard
2. Tax Office Authority
withholding Tax reclaim application including
tax rate is 3. Full beneficiary details provided in shareholder percentage information
lower than completed Tax Questionnaire
sent to client’s tax office for
the treaty
If beneficial owner of assets and income is a certification of residency
rate, the
standard rate mutual fund: Submitted to agent bank in
will prevail. Germany
1. Statement of beneficial ownership in
addition to the above
Greece 5 15* 0/15 0/15 10* Interest: A 0% rate applies to interest on Private Sector Involvement (PSI) bonds. From 1
(Relief at Source January 2014, interest arising on Treasury Bills and Government bonds is exempted from
Territory) 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 0 15* 0 0 10* * Where the standard rate is lower than the treaty rate the former will apply.
(No Tax
Service)
Hungary 0 15* 0 0 10* *Where the standard withholding tax rate is lower than the treaty rate, the standard rate will
(No Tax prevail.Service)
India 0 25* 20 20 15
Interest: Corporate and government bond interest, and interest on foreign currency loans, is
(No Tax subject to a statutory withholding tax rate of 20%. Typically, the Government does not
Service) 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 20 15 20 20* 10
In order to achieve treaty relief, specific forms have to be completed by the beneficial owner.
(Tax Service The treaty relief forms require endorsement by the tax authorities in the relevant entity’s own
upon request) jurisdiction or a Certificate of Tax Residence can be provided.
*0% on foreign currency denominated Indonesian government bond (conventional/sharia
based/sukuk) listed on a foreign market.
Ireland 25 0* 20 0 10* Documentation required from client Forms that RBC Investor & Treasury Services
(Domestic may complete on behalf of client and
*Under the *Where the 1. Power of attorney to enable RBC
Exemption at process/action to be:
DWT scheme standard rate Investor & Treasury Services to
Source/ Reclaim residents of is lower than complete the required forms (one off Clients are initially assigned to a
Territory) treaty countries the treaty rate requirement per Tax Questionnaire, general account to which the
are entitled to the former renewable should details change) maximum withholding tax rate is
full exemption will apply assigned
2. Tax Office details and reference number
on dividend
(one off requirement per Tax Once the certificate of residency
withholding tax
Questionnaire, information update has been received, and if there is a
required should details change) Power of Attorney in place, RBC
3. Tax Office Authority to enable RBC Investor & Treasury Services will
Investor & Treasury Services to request complete a DWT form on behalf of
certifications of residency 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 rateIsrael 25 15 0*/23n interest 0**/23*** 10 Documentation required from client Forms that RBC Investor & Treasury Services
(Relief at Source on publicly Relief at Source & Reclaims: may complete on behalf of client and
traded bonds
Territory)
1. Power of attorney process/action to be:
issued by an
Israeli company 2. AUT 01 (Tax Office Consent) Relief at Source & Reclaims:
and paid to a
3. Full beneficiary details provided A114 form
non-resident,
subject to in completed Tax Questionnaire Certificate of residence
conditions.
Interest: *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 1 26 15 0/26 0/12.5 10 Documentation required from client Forms that RBC Investor & Treasury Services
(Relief at Source may complete on behalf of client and
1. Notarized Power of attorney (2 if assets
process/action to be:
Territory) are going to be held domestically and at
Clearstream) to enable RBC Investor & Once the required information /
Treasury Services to complete the documentation have been
required forms (one off requirement provided by the client RBC
per Tax Questionnaire, renewable Investor & Treasury Services will
should details change) complete an annual certificate on
the client’s behalf to secure treaty
2. If assets are going to be held
relief at source in respect of
domestically and at Clearstream) to
equities.
enable RBC Investor & Treasury
Services to complete the required forms After having received the required
(one off requirement per Tax information / documentation
Questionnaire, renewable should from the client RBC Investor &
details change) Treasury Services will complete a
3. Tax Office details and reference number one off declaration (renewable
(one off requirement per Tax should any details change) on the
Questionnaire, information update client’s behalf to secure exemption
required if details change). at source in respect of interest
income
4. Tax Office Authority to enable RBC
Investor & Treasury Services to request
residency (Details provided 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
multilateral trading facilities, bonds traded in EU/EEA regulated markets and multilateral
trading facilities issued by non-listed 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 15.315 15 0*/15.315 0**/15.315 10 Documentation required from client: Forms that RBC Investor & Treasury Services
(Relief at may complete on behalf of client and
1. Power of attorney
Source process/action to be:
Territory) 2. Full beneficiary details provided in
Application Form for Tax Exemption
completed Tax Questionnaire
3. JGB Exempt Account Declaration
*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 15 15 10* 0 10 *Interest paid to legal entities resident in EEA and DTA countries is exempt
(Tax Service Where the
not applicable) standard rate
is lower than
the treaty
rate, the
standard rate
applies.
Luxembourg 15 15 0 0 10* *Where the standard rate is lower than the treaty rate, the standard rate applies.
(No Tax
Service)
Interest: A 0% rate applies to:
Malaysia 0 15* 0/15 0/15 15
(No Tax i) interest paid or credited to any company not resident in Malaysia (other than such interest
Service) 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 withholding tax rate is lower than the treaty rate, the standard rate will
prevail.Interest: 4.9% rate is applicable to publicly traded debt instruments issued by Mexican
Mexico 10 15* 4.9/10/40 0 10*
entities, to the extent such instruments are registered in the National Securities Register (RNV
(No Tax by its Spanish acronym). If instruments are, un- registered in the RNV, withholding tax will
Service) 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 15 15 10 10 15* *Where the standard rate is lower than the treaty rate, the standard rate applies.
(No Tax
Service)
Netherlands 15 15 0 0 10 Documentation required Forms that RBC Investor & Treasury Services
(Tax Service from client may complete on behalf of client and
Where the
not applicable) process/action to be:
standard rate None required
is lower than None required
the treaty
rate, the
standard rate
applies
New Zealand1 15*/30 15 0/2*/15 0/2/15 10 Documentation required Forms that RBC Investor & Treasury Services
(Relief at Source from client may complete on behalf of client and
*Applies to *2% rate applies Where the
process/action to be:
Territory) fully where standard rate None required
imputed Approved is lower than None required
dividends Issuer Levy has the treaty
been applied for rate, the
standard rate
applies
Norway 1 25 15 0 0 10 Documentation required Forms that RBC Investor & Treasury Services
(Relief at Source from client may complete on behalf of client and
Where the
process/action to be:
Territory) standard rate 1. Power of attorney
is lower than Certificate of Residency
2. Tax Office Authority
the treaty
rate, the 3. Full beneficiary details provided in Form A2
standard rate completed Tax Questionnaire
applies Application for approval sent to
4. Beneficial Owner Declaration
the Norwegian Tax Authorities.
Pakistan 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
(No Tax * of privatized power companies and by companies engaged exclusively in mining operations
Service) 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 thedividend exceeds PKR 2.5 million.
*Filer rate
**Non-filer rate
Investors should consult their tax advisors for further information before investing in
Pakistan.
Peru 5 15* 4.99/30 0 15*
Dividends: 4.1% applies to dividends generated before 2015 fiscal year. The rate was 6.8% for
(No Tax distributions from profits earned in 2015 and 2016.
Service) 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 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
(No Tax credit for taxes deemed payable in the Philippines equivalent to 15%. Due to the restrictive and
Service) 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 19 15 20 20 10
(No Tax Service)
Portugal 25/35** 15 (10) 0*/25/35** 0*/25/35** 10 Documentation required from client Forms that RBC Investor & Treasury Services
(Reclaim may complete on behalf of client and
Territory) 1. Power of attorney process/ action to be:
2. AUT 01 (Tax Office Consent) Tax reclaim application
3. Full beneficiary details provided in Sent to client’s tax office for
completed Tax Questionnaire 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 disclosedRussia 15 15 15*/20 0** 10 Interest:
(Tax Service *A 15% rate applies to interest income on corporate bonds that:
not applicable) - 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 2022.
**15% rate applies to certain types of state and municipal securities
Singapore 0 15* 0/15 0/15 15 Interest: Bonds that qualify as "qualifying debt securities" are exempt from tax.
(No Tax *Where the domestic withholding tax rate is lower than the treaty rate, the domestic rate will
Service) prevail
Slovakia 0 15* 0 0 10* *Where the domestic withholding tax rate is lower than the treaty rate, the domestic rate will
(No Tax prevail.
Service)
South Africa 1 20 15 0*/15 0 10** Documentation required Forms that RBC Investor & Treasury Services
(Relief at from client may complete on behalf of client and
Source/Reclaim process/action to be:
1. Power of attorney
Territory) Reduced Rate of Tax Declaration
2. Tax Office Authority
3. Full beneficiary details provided in
completed Tax Questionnaire
*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 22 15 0*/15.4 0*/15.4 10 Documentation required Forms that RBC Investor & Treasury Services
(Relief at Source from client may complete on behalf of client and
*A 0% rate *An exemption
Territory) process/action to be:
applies to from tax applies to 1. Power of attorney
interest arising interest income Form 72/2 (Application for
2. Tax Office Authority
on foreign arising from
currency Korean Treasury 3. Full beneficiary details provided in Entitlement to reduce the Tax Rate
denominated Bonds and completed Tax Questionnaire on Domestic Sourced Income)
bonds issued Monetary 4. Supporting documentation from an
abroad. Stabilization official source (i.e. CRA) that states that
Bonds acquired the client is a Canadian Insurance
prior to 12 Segregated Fund
November 2010.
Spain 19 15 (4) 0*/19 0*/19 15 Documentation required Forms that RBC Investor & Treasury Services
(Reclaim from client may complete on behalf of client and
A domestic *0% rate applies to
process/action to be:
Territory) exemption is certain 1. Power of attorney
available on Government Quick Refund Procedure:
2. Tax Office Authority
interest from Treasury stock.
Certification of Tax residency
qualifying Interest on public 3. Full beneficiary details provided incorporate bonds debt paid to non- completed Tax Questionnaire requested from client’s tax office
residents without a annually
permanent
Income breakdowns
establishment in
Spain is exempt on Standard Reclaim Procedure:
provision of a Certified Tax Reclaim form
certificate of
residence Income breakdowns
Sri Lanka 14 15 5 0 15 Dividends & Interest: Where the domestic withholding tax rate is lower than the treaty rate,
(No Tax the domestic rate will prevail
Service)
Sweden 1 30 15 0 0 10 Documentation required Forms that RBC Investor & Treasury Services
(Relief at from client may complete on behalf of client and
When the
process/action to be:
Source/ Reclaim domestic Relief at Source & Reclaim:
Territory) withholding Reclaim:
tax rate is 1. Power of attorney
Tax reclaim application
lower than 2. Tax Office Authority
the treaty Sent to client’s tax office for
3. Full beneficiary details provided in certification of residency
rate, the
completed Tax Questionnaire
domestic rate Submitted to agent bank in
will prevail Sweden
Switzerland 35* 15 (20) 35 35 10 (25) Documentation required Forms that RBC Investor & Treasury Services
(Reclaim from client may complete on behalf of client and
*Effective
process/action to be:
Territory) 1st January 1. Power of attorney
2011, Swiss Tax reclaim application
2. Tax Office Authority
companies incorporating shareholder
may pay all 3. Full beneficiary details provided in percentage information
or part of completed Tax Questionnaire
Sent to client’s tax office for
their
If beneficial owner of assets and income is a certification of residency
dividends
tax free mutual fund: Submitted to Swiss Tax
under the Authorities annually
1. Shareholder percentage questionnaire
capital
distribution
principle.
Taiwan 21 15 15 15 10 Interest: 15% on short term bills, Government/Corporate bonds/ Financial Debentures,
(No Tax Securitization Products e.g. ABS, REITs and RAETs, and repos on all of these. 20% applies to
Service) 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 10 10 15 0/15 10 Interest: Government bond interest is exempt from withholding tax in certain cases, eg.
(No Tax interest on a government bond paid by the Thai government to a non-resident individual and
Service) 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 exemptand is subject to the 15% domestic withholding tax.
Turkey 10 20* 0 0 15*
*Where the domestic withholding tax rate is lower than the treaty rate, the domestic rate will
(Tax Service prevail.
not applicable)
UK 1 0 15* 0*/20 0 10* Documentation required Forms that RBC Investor & Treasury Services
(Relief at Source *Where the *0% rate *Where the from client may complete on behalf of client and
Territory) domestic applies to domestic None required process/action to be:
withholding tax interest from withholding
publicly quoted None required
rate is lower tax rate is
than the treaty securities lower than
rate, the the treaty
domestic rate rate, the
will prevail domestic rate
will prevail
US 30 15 0*/30 0*/30 0 Documentation required Forms that RBC Investor & Treasury Services
(Relief at Source from client may complete on behalf of client and
Territory) *0% rate *0% rate applies to process/action to be:
W8-BENE Form (renewable should details
applies to portfolio debt
portfolio debt securities and change, per Tax Questionnaire) It is not possible for RBC Investor
securities and government & Treasury Services to complete
government interest this document on behalf of the
interest 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 0/34 15 34 0 10
Dividends: Dividends are exempt from withholding tax when they are paid out of profits which
(No Tax have been subjected to Income Tax. Payments exceeding taxable profits are subject to
Service) 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 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 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 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. 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.
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