Treasury Management Profile 2016 Kuwait

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1 France Treasury Management Profile 2016

2 Contents Introduction...3 Legal and Regulatory...5 Taxation...7 Banking Payment Instruments Payment Systems Cash Management Electronic Banking Trade Finance Useful Contacts This is one of a series of Guides specifically designed for treasury managers offering a detailed picture of the banking and cash management arrangements for an extensive range of locations. Please note that the information contained in this document is of a general nature only and is subject to change whether for economic, political, social or other reasons. It is not intended to be comprehensive and does not constitute financial, legal, tax or other professional advice on which you should rely. Accordingly you should not act upon the information contained in this document without obtaining your own independent professional advice. The materials contained in this document were assembled in January 2016 (unless otherwise dated) and were based on the law enforceable and information available at that time. We make no representations, warranties or guarantees (express or implied) that the information in this document is complete, accurate or up to date. We will not be liable for any liabilities arising under or in connection with the use of, or any reliance on, this document or the information contained within it. 2

3 Introduction Capital/Other major cities: City/Ahmadi Area: 17,818km 2 Population: 2.79m Language: Currency: Arabic i dinar (KWD) Country telephone code: 965 Weekend: National holidays: Source: Business hours: Banking hours: Stock exchange: Leading share index: Sectoral distribution of GDP (% of GDP): Friday and Saturday Jan, 25, 26 Feb, 24 Apr*, Jun*, 30, 31* Aug, 1 3, 21 Sep*, 1 Dec* Jan, 25, 26 Feb, 14 Apr*, Jun*, 20, 21 24* Aug, 11 Sep*, 20 Nov* 08:30 12:00 and 16:30 20:00 (Sun Thu), 16:30 20:30 (Fri) 08:30 13:00 (Sun Thu) Stock Exchange (KSE) Stock Exchange Index (KWSEIDX) Agriculture 0.4%, Industry 59.4%, Services 40.2% (2015 estimate) * The date shown may vary by plus or minus one day. These dates are derived by converting from a non-gregorian calendar (e.g., Muslim or Hindu) to the Gregorian calendar. Some of these dates cannot be determined in advance with absolute accuracy, even by the governing authorities. In the case of Muslim dates in particular, the feast days are determined by the sighting of a new/full moon. Government Legislature Constitutional monarchy with a unicameral parliament, the National Assembly (Majlis al-umma). National Assembly: 50 members are elected to serve four year terms. Sixteen cabinet members are appointed by the prime minister. Head of state Emir H H Sheikh Sabah al-ahmad al-jaber Al Sabah, head of state since 29 January Political leader Abir Al-Mubarak al-hamad al-sabah, prime minister since 30 November The prime minister is elected every four-years. There is no limit to term length. 3

4 Economy Q3 Q4 Year Q1 Q2 Exchange rate* (USD/KWD) Interest rate* (lending rate)** (%) NA NA NA Unemployment (%) NA NA NA NA NA NA NA Consumer inflation*** (%) NA GDP volume growth*** (%) NA NA NA NA NA GDP (KWD m) 33,078 42,512 48,722 49,392 46,564 NA GDP (USD bn) NA GDP per capita (USD) 38,605 49,375 50,893 48,516 43,644 NA BoP (goods/services/income) as % GDP NA * Period average. ** Weighted average of rates charged by local banks for KWD credit facilities to residents and non-residents. *** Year on year. Sources: IMF, International Financial Statistics, September 2016 and 2015 Yearbook; and World Bank Data. Country credit rating Fitch Ratings rates for issuer default as: Term Issuer Default Rating Short F1 + Long AA Long-term rating outlook Stable Source: January is reliant on oil for revenue petroleum and gas account for 95% of exports and 60% of GDP. The fall in oil prices has corresponded to a steady decline in the country s fortunes. GDP reached just 1.2% in

5 Legal and Regulatory Central bank Established in 1969, the Central Bank of is an autonomous institution operating in accordance with Law No 32 of 1968 concerning Currency, the Central Bank of and the Organisation of Banking Business. Bank supervision The Central Bank of supervises the banking sector in. Resident/non-resident status A shareholding company, a holding company or a limited liability company that is registered in will hold i nationality. Its head office must be in. Commercial companies incorporated abroad may have agencies in, provided that the agent holds i nationality. A commercial company that is incorporated in shall be entered in the Register of Commerce, regardless of whether it has a head office, branch or agency in. Bank accounts Foreign exchange accounts can be held by residents both domestically and abroad. Resident domestic currency (KWD) accounts cannot be held abroad, but are freely convertible into foreign currency. Non-resident bank accounts are permitted in both foreign and domestic currency. Non-resident domestic currency accounts are freely convertible into foreign currency. Interest can be offered on savings accounts. Overdraft facilities are available to residents and non residents. Reporting All transactions between residents and non-residents must be reported to the Central Bank of on a monthly basis for balance of payments purposes. Banks are responsible for submitting transactions data to the Central Bank of on behalf of their clients (although the accuracy of all reported information remains the resident s responsibility). Exchange controls The i dinar (KWD) is s official currency. does not apply exchange controls. is a member of the Gulf Cooperation Council (GCC). The GCC comprises Bahrain,, Oman, Qatar, Saudi Arabia and the United Arab Emirates (UAE). On 1 January 2008, the GCC common market was launched. The common market is expected to lead to monetary union and a single currency between all six GCC member states. Non-resident investors are not permitted to hold more than a 49% stake in i companies. Non-residents are permitted to establish 100%-owned subsidiaries, subject to the stipulations in the Foreign Investment Law, and with prior approval by the Council of Ministers. Anti-money laundering/counter-terrorist financing 1 has enacted anti-money laundering and counter-terrorist financing legislation, including: Law No 106 of 2013, supplemented by several Resolutions and Central Bank of Instructions, specifically Decision No 37 of 2013 On Executive Regulation of Law (106) of 2013, and Ministerial Decision No 5 of 2014 and Law No 85 of is a member of the GCC which is a member of the Financial Action Task Force (FATF). It is also a member of the Middle East & North Africa Financial Action Task Force (MENAFATF). has an established financial intelligence unit, the Financial Intelligence Unit (KFIU), an independent entity operating within the central bank. 1 Data as at March

6 Account opening procedures require formal identification of the account holder and beneficial owner(s). Financial institutions are required to conduct risk based ongoing due diligence. Financial institutions must identify customers making an occasional or series of linked transactions of KWD 3000 and above within 24 hours. Relationships with shell banks are prohibited. Financial institutions in the broadest sense must record and report all suspicious transactions to the KFIU within two working days. Financial institutions are required to keep records of customer identification and of all transactions for at least five years after the business relationship has ended. Any individual who enters with domestic or foreign currency, gold bullion or any other precious materials exceeding KWD 3000 in value must inform the customs authorities. has an established financial intelligence unit, the Financial Intelligence Unit (KFIU), an independent entity operating within the central bank. 6

7 1 Taxation Resident/non-resident The taxable presence of a foreign entity is determined by whether it carries on a trade or business in and not on whether it has a permanent establishment or place of business in. Foreign corporate bodies carrying on a trade or business in are liable to corporate income tax with the exception of entities that are registered in GCC countries and fully owned by /GCC citizens. The term corporate body refers to an association that is formed and registered under the laws of any country or state and is recognised as having a legal existence entirely separate from that of its individual members. Partnerships fall within this definition. Foreign companies can operate in either through an agent (or as the minority shareholder in a locally registered company), or by establishing operations in the Free Trade Zone (operations limited to the Free Trade Zone). There is no difference in principle in the method of calculating taxation in either instance. In the latter case, tax is levied on the foreign company s share of the profits, adjusted for tax (whether or not this is distributed). Tax authority Department of Income Tax. Tax year/filing The tax year is the same as the Christian calendar year, but the Director of Income Taxes may authorise a company to keep its books on a different basis (e.g. if the overseas parent follows a financial year-end other than 31 December). The tax declaration for each taxable period must be submitted within three and a half months of the end of the taxable period. A foreign entity can request an extension of up to 60 days for filing the tax declaration provided a request for an extension is submitted on or before the 15th of the second month following the end of the taxable period; otherwise, the request will not be considered. Tax can be paid as a lump sum or in four instalments on the 15th day of the fourth, sixth, ninth and 12th month following the end of the tax year. If an extension is granted, no tax payment is necessary until the declaration is filed. However, payment must then be made for the first and second instalment. Consolidated returns are not permitted and each company must file a separate return. Corporate taxation Fully i-owned businesses in, or businesses registered in GCC countries, are not liable to income tax. The profits, including capital gains, of foreign corporate bodies from their activities in, are subject to corporate income tax. The company tax rate is 15% and is applied at a flat rate. A tax exemption is possible for profits earned by entities from trading operations on the stock exchange, whether directly or through portfolios of investment funds; for profits generated from activity carried out in the KFTZ; and for profits from activity under the Foreign Direct Investment Law (on a tax credit basis, using certain multipliers). Further, under the Capital Markets Authority (CMA) Law No 22 of 2015, a broad exemption is granted on all remuneration earned by investors through trade on the Stock Exchange; however, the tax department has yet to issue executive circulars regulating the application of this exemption. The maximum deduction for head office expenses is 1.5% for foreign companies operating in through a local agent, and 1% for foreign companies that are shareholders in a KSC (shareholding company) or WLL ( With Limited Liability company). The tax authorities may request that an entity reexamines any expenses deemed to be overstated and to provide documentation supporting the expenses. The authorities have the discretion to approve, adjust or disregard the expenses. 1 All tax information supplied by Deloitte Touche Tohmatsu ( and Deloitte Highlight,

8 A tax exemption for up to ten years, based on a tax credit system using certain multipliers, is available under the Foreign Direct Investment Law No 8 of 2001, as amended by Law No 116 of 2013 and Law No 116 of 2014 on Public Private Partnerships. Entities set up under such laws may also take advantage of other benefits and exemptions, such as those relating to customs duties. There is no surtax or alternative minimum tax. Losses may be carried forward for three years to be offset against future taxable profits. The utilisation of carried forward losses is not permitted if: The entity ceases its activities in (unless the cessation is mandatory); The tax return indicates that there is no revenue arising from the company s main activities; The corporate entity is liquidated; The legal status of the corporate body is changed; or The corporate body has merged with another corporate body. The carryback of losses is not permitted. Advance tax ruling availability Advance tax rulings are not available in. Wealth tax shareholding companies (both listed and non-listed, but excluding government companies) are required to pay 1% of net profits for religious wealth tax (zakat), or as a contribution to the state s budget. The company has an option whether to consider the 1% as zakat or the contribution to the state s budget. Capital gains tax Capital gains derived from the sale of assets are treated as normal business profits and are subject to income tax at the standard rate of 15%. Withholding tax (subject to tax treaties) The general rule is that there is no withholding tax on dividends paid to a non-resident. However, a 15% withholding tax is levied on dividends distributed by fund managers, investment custodians and corporate bodies. There are no withholding taxes on other payments; however, all government departments and companies are required to withhold final payments of no less than 5% of the total amount due to foreign entities until such entities present a tax clearance from the Director of Income Taxes confirming that they have settled all their tax liabilities. Tax treaties/tax information exchange agreements (TIEAs) has exchange of information relationships with 52 jurisdictions through 53 double tax treaties and no TIEAs. Real property tax There are no real property taxes. There is no transfer tax payable on the transfer of property. Thin capitalisation There are no thin capitalisation rules. Transfer pricing The tax authorities deem the following profit margins on the following: Materials imported by entities operating in : 15% on materials imported from the head office; 10% on materials imported from related companies; and 5% on materials imported from unrelated companies. Design work carried out outside : 25% on the design work conducted by the head office; Withholding tax (subject to tax treaties) Payments to: Interest Dividends Royalties Other income Branch remittances Resident companies None None None None NA Non-resident companies None 0/15% None 0%/5% None 8

9 20% on design work conducted by related companies; and 20% on design work conducted by unrelated companies. Consulting work carried out outside : 30% on consulting work conducted in the head office; 25% on consulting work conducted by related companies; and 20% on consulting work conducted by unrelated companies. Stamp duty There is no stamp duty. Other business taxes Of the profits of i shareholding listed companies in, 2.5% is payable to the tax department as National Labour Support Tax. Cash pooling has no specific tax rules for cash pooling arrangements. There is a standard import levy of 5% on the value of imports. Some local industries are protected by higher rates of duty on competing imports. Also, exports are taxed at 5% unless they are imported items that have been exported. Financial transactions/banking services tax There are no specific financial transactions/banking services taxes in. Payroll and social security taxes has no payroll tax. Employers and i employees are required to make monthly social security contributions, based on monthly salaries. Under social security law, the employer s contribution is 11.5% and the employee s contribution is 8%. The salary ceiling for social security contributions is KWD 2750 per month. The employee s contribution is deducted directly from wages before transferring amounts to the employee s bank account. Social security contributions are limited to i employees only. Sales taxes/vat There are no consumption taxes in. 9

10 Banking Overview There are 11 domestic commercial banks operating in. These include five Islamic banks ( Finance House, Boubyan Bank, International Bank of, Ahli United Bank and Al Rahji Bank) and one investment bank (the Industrial Bank of ). There are also 12 branches of foreign banks. s banks operate 419 branches across the country, with 244 conventional branches and 163 Islamic bank branches. The i banking sector is dominated by two banks, the National Bank of and Finance House. Together these two banks control approximately 56% of the banking sector s total assets. Islamic banking practices are well-established in ; Islamic banks account for approximately 39% of the sector s assets. There are five banks licensed to provide Sharia-compliant products, in addition to a non-i Islamic bank branch. The Commercial Bank of has announced plans to convert to an Islamic bank. The i government has made some effort to divest its ownership stake in the banking sector. However, a number of local banks ( Finance House (25% state-owned), Warba Bank (76% stateowned) and Gulf Bank (18.3% state-owned)) continue to have substantial government ownership. Foreign banks, including BNP Paribas, Citibank, HSBC and Industrial & Commercial Bank of China, are present in, but severe restrictions apply to their operations there. Foreign banks are permitted to open multiple branches in the country (though the Central Bank of will still approve new branches on a case-by-case basis) and to open representative offices. However, they are restricted to offering investment banking services only. Major banks Bank Total assets (USD millions) 30 September 2016 National Bank of 82,235 Finance House 55,198 Burgan Bank 23,548 Gulf Bank 18,643 Commercial Bank of 13,422 Source: January

11 Payment Instruments Cash Cash is an important payment medium in, particularly for low-value retail and commercial transactions. Credit transfers All credit transfers in are automated. Credit transfers are cleared and settled via KASSIP, the national RTGS system, on a same-day basis. There is no value threshold. Credit transfers include salary, supplier and third-party payments. Direct debits Direct debits are available in for low-value recurring payments such as utility bills. Interbank direct debits are cleared and settled via KASSIP. Funds are available to beneficiaries on a T+3 basis. Cheques accounted for 55.5% of the value of all cashless payments in the fiscal year 2014/15, but just 2.6% of the volume. Cheques The cheque remains a common cashless payment instrument for both retail and commercial payments. Cheques accounted for 55.5% of the value of all cashless payments in the fiscal year 2014/15, but just 2.6% of the volume. All KWD-denominated cheques are exchanged and cleared electronically between banks. Settlement is on a T+1 basis. Non KWD-denominated cheques are manually cleared. In the fiscal year 2014/15, 2.4 million domestic currency cheques were processed, with a total value of KWD 13.5 billion. Card payments The use of payment cards in, particularly of debit cards, is becoming increasingly popular. There were 3.9 million payment cards in circulation at the end of December Of these, three million were debit cards and 615,800 were credit cards. Visa and MasterCard are the principal credit card brands issued. In 2016, Boubyan Bank launched s first contactless payment card. Each bank in establishes its own individual clearing and settlement arrangements with the card associations. There were 1,632 ATMs and 38,316 POS terminals in at the end of All ATM and POS terminals are interconnected via KNET. KNET also connects the country s ATM network to the ATM networks of its fellow GCC member states (via the GCCNet ATM network). In 2014, there were 81.5 million ATM transactions processed, worth a total of KWD 10.6 billion; there were million POS transactions, worth a total of KWD 7.6 billion. Electronic money schemes are available in the form of reloadable pre-paid cards. 11

12 Payment Systems Type KASSIP ( Automated Settlement System for Inter-participant Payments), s national real-time gross settlement (RTGS) system, is operated by the Central Bank of. In 2014, KASSIP processed 1.33 million transactions, with a value of KWD 304 billion. The KECCS ( Electronic Cheque Clearing System), an automated cheque clearing system, was launched in June The KECCS is operated by the Central Bank of. Participants KASSIP participants include the Central Bank of and all licensed banks. All banks can participate in the KECCS. Transaction types processed KASSIP processes all KWD interbank transfers. There is no value threshold. In addition, KASSIP effects the final settlement of all other payment instruments. The KECCS processes all KWD-denominated cheque payments. Operating hours KASSIP operates from 08:00 to 14:30 AST (Arabia Standard Time), Sunday to Thursday. Clearing cycle details KASSIP KASSIP settles transactions in real time and with immediate finality. Payment instructions are submitted using SWIFT messages or via the central bank s private WAN network i.e. CBK Net. Settlement takes place across the participant banks correspondent accounts at the Central Bank of. KECCS Cheques are scanned and processed by bank tellers before being processed via the KECCS. Final settlement takes place across the participants accounts held at the Central Bank of via KASSIP. Currency centre holidays Jan, 25, 26 Feb, 24 Apr*, Jun*, 30, 31* Aug, 1 3, 21 Sep*, 1 Dec* Jan, 25, 26 Feb, 14 Apr*, Jun*, 20, Aug* 11 Sep*, 20 Nov* * The date shown may vary by plus or minus one day. These dates are derived by converting from a non-gregorian calendar (e.g., Muslim or Hindu) to the Gregorian calendar. Some of these dates cannot be determined in advance with absolute accuracy, even by the governing authorities. In the case of Muslim dates in particular, the feast days are determined by the sighting of a new/full moon. Source: The KECCS automated cheque clearing system was launched in June It is operated by the Central Bank of. Cheques are cleared on a same-day basis if presented before a bank s cut-off time (10:00), or within one working day if presented after the cut-off time. 12

13 Cash Management Domestic Notional pooling Notional pooling is permitted between resident and non-resident companies, but regulatory restrictions can make it difficult and expensive to operate. Cash concentration Cash concentration is permitted between residents and non-resident companies. Cross-border cash concentration is permitted, but not widely available. Collections Several banks in offer cash collection and account receivables services to corporate clients. Cross-border Cross-border payments are routed via SWIFT and settled through accounts held with correspondent banks abroad. Lifting fees Banks do not distinguish between resident and nonresident accounts in terms of fee structure. Short-term investments Interest can be earned on resident and non-resident savings accounts, but is not typically offered on current accounts. Demand and time deposits are available in KWD or major foreign currencies. Interest is typically paid on the maturity date for time deposits, and on a periodic basis for other deposit accounts. Time deposits can have maturities ranging from one week to five years. Treasury bills (T-bills) are issued by the government with maturities of three to six months. (The Central Bank of has not issued three-month T-bills since May 2012 and no six-month bills have been issued since 2009.) Short-term government bonds are available with maturities of three and six months, with longer maturities ranging from one to ten years. Commercial paper is offered by companies, while certificates of deposit are offered by commercial banks. Both have maturities of up to one year. Money market funds are available for short tenors up to one week. Institutions provide liquidity in KWD for up to 11 months. Repurchase agreements are available. Custody and securities settlement 1 Depository Clearing Company SAK (KCC). The KCC is the central clearing, settlement and depository entity for the i securities market. The KCC provides clearing, settlement, depository services to all KSE-traded securities and derivatives. The KCC provides depository services for unlisted equity securities and debt instruments. It also provides registrar and trustee services to companies and investment funds, and performs local and regional custody services for both local and foreign investors. The KCC is the central registrar for the KSE and the National Numbering Agency. It also provides regional custody services in GCC markets through its network of sub-custodians. After the close of trading, the KSE delivers trade data electronically to the KCC, whose clearing and settlement system matches buys and sells and settles the trades on a gross basis. Investors who hold both share and cash accounts with the KCC are obligated to pay the KCC on T. Upon settlement, the securities and cash elements of the trades are recorded in the investors accounts at the KCC. BIS Model Model 1. Settlement cycle Generally T. T+2 for foreign investors. 1 Data as at February

14 Electronic Banking Electronic banking is available in and offered by the majority of the country s banks. There is no bankindependent electronic banking standard; each bank offers its own proprietary system for corporate banking purposes. Electronic banking services include balance and transaction reporting and payment initiation. Internet banking is offered by s leading commercial banks and is popular among both retail users and small companies. There were approximately 2.4 million internet users in in 2014, a penetration rate of 86.9%. Approximately 52% of users accessed online banking services. Tasdeed, an e-payment system, facilitates the online payment of utility bills, legal fees and traffic fines. Mobile banking is offered by the country s leading commercial banks. Account holders are able to access account information such as balance and transaction information via SMS messages, and to make utility bill payments. There are an estimated 8.3 million mobile phone subscribers in ; smartphone penetration is in excess of 86%. There were approximately 2.4 million internet users in in 2014, a penetration rate of 86.9%. Approximately 52% of users accessed online banking services. 14

15 Trade Finance Trading partners Import USA 12.7%, China 11.9%, Saudi Arabia 7.1%, South Korea 6.9%, Japan 6.6%, Germany 4.8%, India 4.2%. Export South Korea 16.7%, India 14.9%, Japan 12.2%, USA 11.3%, China 9.9%. Source: The World Factbook Washington, DC: Central Intelligence Agency, 2013 ( Imports Documents In order to import goods into, a customs declaration, commercial invoice (including a full description of the imported goods), bill of lading, packing list and certificate of origin are required. Licences Licences are required for all imports except for fresh fruits and vegetables, wheat and flour. The importer must be at least 51% domestically owned. Taxes/tariffs and other fees is a member of the Gulf Cooperation Council (GCC). The GCC comprises Bahrain,, Oman, Qatar, Saudi Arabia and the UAE. A GCC Customs Union with a common external tariff came into effect in No import tariffs apply to imports from within the GCC. As a member of the Greater Arab Free Trade Area (GAFTA), has eliminated most trade tariffs with GAFTA s other member states. GAFTA has established a bilateral free trade agreement with the USA. A customs duty of 5% is generally applied to imports from outside the GCC. Higher rates apply to imports of industries where the domestic producers provide a minimum 40% to the i market. The local valueadded content of the goods imported determines the rate of tariff imposed. Protective duties of 15%, 20% and 25% apply to goods imported when the local value-added content of goods of i origin is at least 20%, 30% or 40% respectively.protective duties are 5% lower for imports of consumer goods. Imports competing with goods of i origin are subject to a maximum duty of 100%. Import duties do not apply to food items, raw materials and spare parts, or to certain types of machinery and equipment. Prohibited imports A negative list (of products that may not be imported) is in operation. It is prohibited to import certain commodities into, in order to protect fauna and flora, and for national security and moral reasons. Importing certain weapons, certain foodstuffs, alcoholic beverages and tobacco is prohibited. Imports from Israel are prohibited. Exports Documents In order to export goods from, a customs declaration, commercial invoice, bill of lading, packing list and certificate of origin are required. Licences In times of shortages or emergency, special licences are mandatory for exporting restricted quantities of certain agricultural products and cement. Licences are required for exporting armaments and ammunition. Taxes/tariffs and other fees No taxes are charged on exports from. Prohibited exports A negative list (of products that may not be exported) is in operation. It is prohibited to export certain agricultural products when domestic demand outweighs supply. Exporting items to Israel is prohibited. 15

16 16 In times of shortages or emergency, special licences are mandatory for exporting restricted quantities of agricultural products and cement. Financing imports and exports Imports There are no financing requirements for imports. Exports There are no financing requirements for exports.

17 Useful Contacts Central Bank of Leading banks: Burgan Bank Commercial Bank of Gulf Bank Finance House National Bank of Financial Markets Association Ministry of Finance Chamber of Commerce & Industry Investment Authority Stock Exchange HSBC contact details HSBC Commercial Banking HSBC Global Banking and Markets This document is produced by HSBC Bank plc and members of the HSBC Group, together with their third-party contributor. It is not intended as an offer or solicitation for business to anyone in any jurisdiction. The information contained in this document is of a general nature only. It is not meant to be comprehensive and does not constitute financial, legal, tax or other professional advice. You should not act upon the information contained in this document without obtaining your own independent professional advice. The views and opinions expressed by the third-party contributor are their own and not necessarily those of HSBC. The information contained in this document has not been independently verified by HSBC. This document contains information relating to third parties. The information does not constitute any form of endorsement by these third parties of the products and/or services provided by HSBC or any form of cooperation between HSBC and the respective third parties. Under no circumstances will HSBC or the third-party contributor be liable for (i) the accuracy or sufficiency of this document or of any information, statement, assumption or projection contained in this document or any other written or oral information provided in connection with the same, or (ii) any loss or damage (whether direct, indirect, consequential or other) arising out of reliance upon this document or any opinion or statement made in this document. All efforts have been made to ensure that the information contained is current at the first date of publication. HSBC and the third-party contributor does not undertake, and is under no obligation, to provide any additional information, to update this document, to correct any inaccuracies or to remedy any errors or omissions. No part of this document may be reproduced, stored in a retrieval system or transmitted in any form or by any means, electronic, mechanical, photocopying, recording or otherwise, without the prior written permission of HSBC and the third-party contributor. Any products or services to be provided by HSBC in connection with the information contained in this document shall be subject to the terms of separate legally binding documentation. 17

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