Tax Desk Book. ISRAEL S. Horowitz & Co

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1 Introduction Tax Desk Book ISRAEL S. Horowitz & Co CONTACT INFORMATION: Leor Nouman Ophir Kaplan S. Horowitz & Co. 31 Ahad Ha'am Street Tel-Aviv Israel ( ) 1. Please give a brief overview of the types of taxes imposed in your jurisdiction (i.e., direct and indirect taxes and their components.) The main taxes applied in Israel today are as follows: Direct taxes (taxes on income and gains): a. Income tax (individuals); b. Corporate tax; c. Capital gains tax; d. Land appreciation tax. Indirect taxes (taxes on transactions): a. Value-added tax (VAT); b. Customs and duties; c. Purchase tax.

2 Property Taxes: a. Local municipal taxes (e.g., Arnona, water and sewage rates, road charges, etc.); b. Betterment levy. Employment taxes: a. National insurance contributions; b. National health insurance tax. INCOME TAXES AS APPLIED TO BUSINESS ENTITIES AND INDIVIDUALS Calculation of Income/ Profit Taxes 2. How is the taxable base determined? Generally, Israeli residents are obliged to pay income/corporate tax on their worldwide income which was produced or accrued from any of the fixed list of sources (e.g. business income, vocation or employment income, dividends, interest and linkage differentials, patents and copyrights, rent, etc.). Foreign residents are liable to pay income/corporate tax in Israel on income produced or accrued in Israel from the sources referred to above (unless such foreign resident is exempt from tax). A Company s income and costs are recorded, in most cases, on an accrual basis, in accordance with their financial reports. In addition, the sale of capital asset is subject to capital gains tax. When calculating the sum of capital gains tax payable, certain basic principles need to be taken into consideration. In this context, an Israeli resident is liable to tax on a capital gain accrued or produced in Israel or abroad. A foreign resident is similarly liable to tax on a capital gain accrued or produced in Israel. The place where the capital gain was generated or accrued shall be deemed to be in Israel, in any of the following instances: the asset being sold is located in Israel; the asset being sold is located abroad and, essentially, constitutes a direct or indirect right to an asset or to inventory or constitutes an indirect right to real estate or to an asset in a real estate company located in Israel ( the Property ), in respect of that part of the consideration that stems from the Property located in Israel; the asset comprises a share or a right relating to a share in an Israeli resident body of persons;

3 the asset comprises a right in a foreign resident body of persons which constitutes essentially a direct or an indirect right to Property located in Israel, in respect of that part of the consideration that stems from the Property located in Israel. 3. What revenues are included? The income/corporate tax base includes income which was produced or accrued from any of a fixed list of sources (e.g. business income, vocation or employment income, dividends, interest and linkage differentials, patents and copyrights, rent, etc.) 4. What deductions are allowed? An assessee can deduct all types of expenses which were 'wholly and exclusively' incurred during the tax year and which relate to the production of income by such assessee, unless such deduction is limited or disallowed. Part of the permitted deductions is established by statute, for example: interest, depreciation, rent, repairs, bad debts, preparing accounts, R&D, etc. Depreciation allowances are available, in general, for tangible assets and goodwill. In certain circumstances the assessee may be entitled to accelerated depreciation. 5. What are the major expenses that are not deductible? The major expenses which are excluded from deductibility are: private expenses, capital withdrawn or a sum used as capital, the cost of improvements, any loss or expense which is recoverable under insurance or under a contract of indemnification, amounts paid as income tax (including interest and penalties accruing thereon), premiums paid by a company to insure the life of a controlling member (a person who holds, directly or indirectly, at least 10% of the issued share capital or the voting power of the company or the right to receive at least 10% of the company s profits or the right to appoint a director in the company), expenses in respect of a benefit granted by an employer to his employees which cannot be attributed to a particular employee, or education expenses. Capital expenditure will be taken into consideration on the date of sale of the asset (having regard to the calculation of the capital gain) and, until such date of sale, by way of depreciation. 6. What are the applicable federal rates?

4 In Israel only national tax is payable on income. The main direct tax rates for the 2009 tax year are as follows: (a) Income tax The relevant income tax rates for the 2009 tax year with respect to income derived from 'personal exertion' (generally, income earned by individuals, whether selfemployed or salaried employees, constituting work income and certain other income) are as follows: Taxable Income (NIS) Rate of tax Up to 55,080 10% From 55,081 to 97,920 15% From 97,921 to 147,000 23% From 147,001 to 211,200 30% From 211,201 to 454,680 34% More than 454,680 46% (b) Corporate tax The rate of corporate tax payable for the 2009 tax year is 26%. Such rate may be reduced for certain periods of time with respect to investments and/or activities that are recognized under the Capital Investments Law. In addition, such rate as well as the income tax rates (individuals) is expected to be lower in the following tax years. (c) Land appreciation tax Generally, the land appreciation tax rate on real capital gains (that is, the capital gain minus inflation) is: 20% (individuals) or 25% (corporations) for part of the capital gain that accrued after November 7, The regular income/corporate tax rate that applies for income earned by an individual or a company (as applicable) on the date the asset is sold (i.e., up to 46% for individuals or 26% for corporations for sales made in the 2009 tax year) for part of the appreciation that accrued before November 7, 2001 (if any). Determination of the real land appreciation tax prior to and after November 7, 2001 will be made using the linear method. The tax rate on the inflationary amount is 10% with respect to that part of the inflationary amount which accrued until December 31, 1993 and zero-rated with respect to that part of the inflationary amount accruing after such date. With respect to the sale of real estate assets which were acquired up until April 1, 1961, the tax rate regarding the nominal appreciation may be lower (usually, the tax rate applicable for entire gain may range between 12%-25%).

5 When calculating the land appreciation tax payable, certain basic principles must be considered (for example, type of asset, transferring party's identity, deductible expenses, tax exemptions and set-off of losses). 7. What are the applicable state and/ or other local rates? N/A. See our answer above. 8. What are the applicable capital gains rates and base, if different and concessional tax treatment in case of business re-organization such as amalgamation, slump sale, demerger, etc? In Israel, only national tax is imposed on capital gains. The tax rate on real capital gains (i.e., the capital gain less the inflationary amount) is, generally, 20% (individuals) or 25% (corporations) with respect to that part of the capital gain accruing after January 1, 2003 (however, see also below regarding individual's tax rate in case of a sale of certain types of assets); the applicable tax rate with respect to that part of the capital gain which accrued prior to January 1, 2003 is the marginal income tax rate (individuals) or the regular rate of corporate tax (corporations) applicable on the date of sale of the relevant asset. If an asset was purchased prior to January 1, 2003 and then sold after such date, the division (for the purposes of calculation of the tax liability) of the accrued capital gains will be made by way of the linear method. The tax rate on the inflationary amount is 10% with respect to that part of the inflationary amount which accrued until December 31, 1993 and zero-rated with respect to that part of the inflationary amount accruing after such date. The tax rate on capital gains from the sale of goodwill for acquisition where no consideration has been paid, is 25% (including that part of the capital gain which accrued prior to January 1, 2003). In addition, the individual's capital gains tax rate may be either 15%, 20% or 25% in case of capital gains accrued on securities, while the tax rate depends, mainly, upon the type of security involved and/or the rate of holdings of means of control in the corporation In the event of a sale of shares in an unlisted company that were purchased before 2003 by an individual, the seller may be entitled to an additional inflationary amount, based on such seller s proportional share of retained earnings of the company. The tax rate on the real capital gain, equal to the seller s share in the profits available for

6 distribution (i.e., profits accumulated in the company during the period between the end of the tax year prior to the year in which the shares were acquired - but occurring not before January 1, and the end of the tax year prior to the year in which they were sold, based on certain methods of calculation) which accrued until January 1, 2003, is 10% and the tax rate on the real capital gain equal to the seller s share in the profits available for distribution accruing after January 1, 2003 is 20% or 25%. Israeli income tax laws include several repr 9. How are operating losses handled? In general, losses arising from a trade or business may be carried forward (but can not be carried backward) to be set-off against any other income of the assessee which was produced or accrued in the same tax year, or against business income (including capital gains income accrued within the business) indefinitely. Other type of losses (i.e., a loss which had it been a profit would have been liable to tax as passive income, like income from interest, rent or royalties) may only be set-off against income accrued from the same type of source. Likewise, the Israeli tax law includes several limitations regarding the set-off of losses incurred outside Israel. 10. How are capital losses handled? Generally, capital losses can be carried forward to be set-off against capital gains only. In a case where the capital loss was incurred from the sale of an asset outside Israel, then the capital loss shall first be set-off against a capital gain from out Territorial Rules 11. What are the residence rules? The residence rules are, generally, as following: Individual An Israeli resident for taxation purposes is an individual whose life is centered in Israel. In order to determine the place where an individual s life is centered, certain factors would need to be taken into account, such as the individual s family, economic and social ties, including ( the Center of Life Test ):

7 his place of permanent residence; the place where he and his family reside; his permanent place of business or the place where he is employed; the place of his active and substantive economic interests; and the place where his activity in organizations and various institutions takes place. In addition, it is assumed as a presumption that the individual s life is centered in Israel in a tax year if: (a) he spent 183 days or more of that tax year in Israel; or (b) he spent thirty days or more in Israel within that tax year and the total period of his stay in Israel in the tax year and in the preceding two tax years amounted to 425 days or more ( the Stay Assumptions ). Such assumptions may be refuted both by the individual and by the Israeli tax authorities. However, certain types of individuals may not be classified as Israeli residents (e.g., students, foreign journalists, sportsmen, diplomatic representatives and sick persons), in certain circumstances even if a person is considered as having his center of life in Israel in a certain tax year due to the Center of Life Test and the Stay Assumptions. Please note that even if a person is considered as having his center of life in Israel in a certain tax year due to one (or more) of the Stay Assumptions, such person can still try to rebut the assumption through the application of the Center of Life Test and prove that he should not be considered as an 'Israeli resident' for that tax year. In addition, please also note that in the event that an individual is considered to be an 'Israeli resident' according to Israel internal tax law (i.e., with respect to the Center of Life Test and the Stay Assumptions) and is also considered a resident of another country due to such other country s internal laws, then the provisions of the relevant Tax Treaty (if any) shall apply in order to determine the tax residency of such individual and to prevent the imposition of double taxes on that individual. In light of the fact that the relevant provisions of the Tax Treaties which Israel has signed and ratified 12. Is worldwide income taxed? Israeli residents are obliged to pay income/corporate tax on their worldwide taxable income. Foreign residents are liable to pay Israeli income/corporate tax on income produced or accrued in Israel.

8 13. Tax credits - Are there tax credits relating to legal dispositions other than provisions in Double Taxation Treaties, on the possibility of deducting taxes paid abroad, or any others? Generally, the Israeli tax law provides that foreign taxes paid on foreign income (i.e., taxes payable by an Israeli resident to tax authorities of a state other than Israel, on income produced or accrued in that state) shall translated into new shekel amounts be allowed as credits against Israel income/corporate tax payable by said Israeli resident. However, there are certain limitations in connection with entitlement to use these credits: for example, the amount of credit against corporate tax, to which an Israeli resident body of persons is entitled with respect to foreign income, shall not exceed the amount of Israeli corporate tax to which it is liable on that income (certain limitation also exists with respect to excess credit of individuals). In addition, the method of credit in Israel is based upon the classification of foreign income under a 'Baskets method' (i.e., the foreign income is classified by the different Israeli sources of income, and a foreign tax paid on foreign income from certain sources may be credited against Israeli tax paid on income from the same source). Withholding Taxes 14. What are the rates on dividends for withholding taxes? A withholding tax rate of 20% or 25% will apply, subject to any equivalent provision in a double tax treaty which may reduce such rate. The withholding tax rate of 25% is applicable, mainly, for dividend receivers that are either corporations or individuals whom are substantial shareholders (defined as a person that holds, directly or indirectly, alone or with another person, at least 10% of any type of means of control in the company, on the date of receipt of the dividend or on any date falling within the 12 month period preceding payment of such dividend). In the case of dividends paid by an 'Approved Enterprise' or a 'Beneficiary Enterprise'' (as such terms are defined for the Encouragement of Capital Investments Law purposes), the rate of withholding tax may be lower (e.g., 15% or 0%). 15. What are the rates on royalties for withholding taxes? In most cases, a withholding tax of 25% (individuals) or 26% (for corporations however, this rate is applicable for the 2009 tax year and may be lower in the subsequent tax years) will apply on royalties.

9 16. What are the rates on interest for withholding taxes? Various withholding tax rates have been fixed with respect to payments of interest income, which are dependent upon the residency status and type of person/entity receiving such interest income payments, the payor, etc. In most cases, a withholding tax of 20% (individuals) or 26% (corporations with respect to the 2009 tax year) will apply on interest. However, interest income payments to foreign resident individuals who are usually taxed at source at a rate of 25% unless the foreign resident individual has been exempted from tax (e.g., with respect to interest income on foreign currency deposits in specified conditions) or is entitled to a lower withholding tax rate under an approval given by the tax authorities. In addition, in certain circumstances the rate of withholding tax on interest income payable to individuals is the maximal income tax rate (e.g., 46% for 2009 tax year). 17. What are the rates of withholding tax on profits realized by a foreign corporation? In most cases, a withholding tax of 26% will apply on income payments to foreign corporations (however, this rate is applicable for the 2009 tax year and may be lower in the subsequent tax years), unless the foreign resident corporation has been exempted from tax or that the tax authorities have permitted the income to be paid without deduction of tax (i.e., if it has been proven to their satisfaction that the tax already was paid or that it will be paid in some other manner). 18. Please list any other rates on withholding taxes that we should be aware of. The general withholding tax rate for rendering of services or transfer of assets is 20% or 30% (unless a reduced tax rate or an exemption from withholding of tax was approved by the tax authorities in advance). The withholding tax rate for employment income is the full income tax applicable for such income. The general withholding tax rate for rental is 35%. Tax Returns and Compliance 19. What is the taxable reporting period? Israel's income tax year runs from January 1 to December 31.

10 20. What are the due dates for the filing of tax returns? A company is generally required to file a tax return annually, not later than five months after the end of the tax year (i.e., until May 31 of the subsequent calendar year). If the company s tax return is not based on a complete set of double entry accounts, then it shall deliver the return by not later than April 30 of each subsequent year. If an individual is required to submit a tax return, then the date for submitting same must be no later than four months after the end of the relevant tax year (i.e., until April 30 of the ensuing year in which the income was generated). If an individual s tax return is based on a complete set of double entry accounts or that he/she should submit an online independent return, and then such individual is required to submit the tax return by no later than May 31 of each subsequent year. 21. What are the key compliance requirements? The tax return must include details of the profits which are taxable, specify each source of income and the amounts arising from the source, as well as the special rates of tax applicable to that income. The assessee must give details of asset disposals and any capital gains or losses arising. Details of asset acquisitions may be given for the purposes of calculating depreciation allowances. 22. Are there any other requirements that we should be aware of regarding tax returns and compliance? Generally, every assessee is required to make advance payments (usually, the advance payment with respect to the relevant month constitutes 10% of the amount of tax for which the assessee is liable in the determining year and must be paid on the fifteenth day of each of the ten months falling from February to November in each tax year; however, another alternative to determine the scope of the advance payment is based on an agreed percentage of turnover). Other than its obligation to make a monthly advance payment to the tax authorities, the assessee is obliged to pay his/its tax upon the submission of the tax return or within fifteen days after delivery to the assessee of a notice of assessment from the Israeli tax authorities. INDIRECT TAXES 23. Are there any indirect taxes in your jurisdiction?

11 There are some indirect taxes in Israel which apply, mainly, with respect to the sale of assets or rendering of services. The principal indirect taxes are: Value-added-tax (VAT); Purchase tax and customs duties; Acquisition tax (real estate). 24. How does it operate? Is it a VAT or a sales tax? VAT In general, the sale of an asset (real estate or goods, but excluding securities) or the rendering of a service in the course of a business ( transaction ) made or performed in Israel and the importation of goods are subject to Value Added Tax ( VAT ). A foreign resident who engages in business or has a presence or activity in Israel is liable to pay VAT in Israel. In such a case, he is required, within thirty days after the commencement of his business activities in Israel, to appoint a representative, having a permanent place of residence in Israel, to act on behalf of such foreign resident for VAT purposes as well as for any and all income taxes payable by the foreign resident to the Israeli tax authorities. Purchase Tax and Customs Duties Other types of indirect taxes payable are purchase tax and customs duties. Purchase tax is imposed, generally, on the importation or sale of certain types of goods (e.g., motor vehicles). Acquisition Tax Upon the sale of a real estate right, the purchaser shall be liable to pay real estate acquisition tax. 25. How is the taxable base determined? For the purposes of most types of indirect taxes, the taxable base is, generally, the sale price. 26. What are the applicable rates? The applicable rates are as following:

12 VAT - the current rate of VAT in Israel is 15.5% of the value of the transaction. Such rate may be raised to 16.5% soon according to certain governmental proposal. Purchase tax and customs duties - The respective rates of purchase tax and customs duties vary from one product to another. Acquisition tax the rate of acquisition tax is 0%-5% of the sale price for residential apartments and acquisition tax at the rate of 5% in respect of other real estate rights. 27. Are there any exemptions? Different types of exemptions may be relevant for indirect taxes. The principal ones are: VAT - certain transactions are VAT-exempt or zero-rated [such as transactions between Israeli residents and foreign residents in specified conditions (for example, the export of tangible or intangible goods, the rendering of services to a foreign resident, etc.) and transactions involving the implementation of certain structural changes to a business and other restructuring activities]. Purchase tax and customs duties the importation of certain types of products may be exempted from purchase tax and customs duties. Acquisition tax certain reprieves are available with respect to acquisition tax, such as if the purchaser is an immigrant or a disabled person (under certain conditions). 28. Are there any other taxes such as debit or financial transactions taxes enforced in you jurisdiction? Generally, the answer is no. With respect to VAT however, please note that, in most cases, the transfer of a debt is not subject to VAT. Although a loan is considered a right and is included in the definition of an asset in the VAT Law, in practice, VAT is applicable only with respect to the interest included in the price and not on the principal of the loan. For example, VAT is not payable when the debt is transferred by means of a security or a merchantable document. There is no definition of "merchantable document" in the VAT Law, but it can basically include any document, where the transfer of which gives rise to the transfer of the rights attached to it (for example, a debenture or a promissory note). PARAFISCAL CONTRIBUTIONS

13 29. Are there any parafiscal contributions (i.e. social security, science and/ or technology)? There are two types of parafiscal contributions that apply in Israel: a. National insurance contributions; b. National health insurance tax. 30. How do they operate? Generally, with respect to social security liability, every individual Israeli resident over the age of eighteen years is required to purchase National Insurance and National Health Insurance and, for such purposes, must make the necessary national insurance contributions and pay the national health tax duties. The tests adopted by Israeli courts for the determination of residency for social security purposes are quite similar to those adopted for income tax purposes (i.e., the Center of Life Test which is based, generally, on the individual s family, economic and social ties). With respect to salaried employees, it should be noted that the employer has, in addition to withholding obligations for income tax liabilities, withholding obligations for employee social security liabilities, as well as for the employer s own social security liability. However, certain salaried employees are required to pay the national insurance contribution themselves (i.e., instead of such contribution being withheld by their employer), including, inter alia, an employee whose employer is not an Israeli resident and where the employer s place of residence is not Israel and the employer has no address in Israel to receive legal documents, or where the employer is an international organization entitled to immunity as a consequence of an international convention to which Israel is a party. 31. How is the taxable base determined? National insurance contributions and health insurance taxes are calculated as a percentage of the individual s taxable income. 52% of the above-mentioned contributions are tax deductible. 32. What are the applicable rates?

14 The national insurance duties and health insurance contributions rates applicable to employers and employees (the maximum monthly taxable income (cap) for both types of duties is NIS 38,415 for the 2009 tax year) are as following: Share of the income that is up to 60% of the average wage ( NIS 4,757) Employer Employee Total National insurance 3.45% 0.4% 3.85% Health insurance % 3.1% 3.45% 3.5% 6.95% Share of the income that is above 60% of the average wage and up to the cap Employer Employee Total National insurance 5.43% 7% 12.43% Health insurance % 5% 5.43% 12% 17.43% 33. Are there any exemptions? Certain exemptions from social security duties are applicable, some of them depend upon the status of the individual (e.g., a soldier, a prisoner, a new immigrant or a housewife) and the balance depends upon the type of income (for example, capital gains and passive income are, in most cases, exempted from said taxes). INHERITANCE AND GIFT TAXES 34. Are there inheritance taxes, gift taxes or any other taxes like Wealth Tax, etc.? No 35. If you answered yes to the question above, please describe what triggers the requirement for the tax, what the rate of tax is, and what is included in the taxable base. N/A OTHER MATTERS

15 36. Are there any tax incentives granted for various matters such as research and development, investment in certain industries/ areas, etc.? Yes 37. If so, please indicate if there are any of the following: anti-deferral regimes; transfer pricing provisions; tax avoidance measures like legislated General Anti- Avoidance Rules, etc.; controlled foreign companies regulations; thin capitalization rules Some other regimes that are also exist in Israel include the following: Transfer Pricing According to the Israeli transfer pricing regime, if in an international transaction there exists a 'special relationship' between the parties thereto (e.g., relations of control of one party to a transaction over the other or if both parties are controlled by the same entity) and the price for a particular asset, right, service or credit has been determined (or other conditions prescribed therefore) so that a profit is smaller than that which would have been earned had the price or conditions been fixed between parties having no such special relationship (fair market value), then a report of such transaction must be made in accordance with market conditions and taxes levied thereon accordingly. The said regime also deals with the manner for determining whether the price for a particular transaction is compatible with the market price. Controlled-Foreign-Companies (CFC) In general, if a controlled foreign company ( CFC ) has "unpaid profits", then its controlling member (i.e., an Israeli resident who, directly or indirectly, alone or together with another, holds at least 10% of one of the means of control in the CFC at the end of the tax year or on any day during the tax year and on any day in the subsequent tax year) shall be treated as if he had received his proportional share of the unpaid profits by way of a dividend ( Deemed Dividend ). A CFC is defined as a foreign resident body of persons which, inter alia, meets the following cumulative conditions: its shares are not listed for trade on a stock exchange or, they are listed on such an exchange, but less than 30% of the rights therein are offered to the public;

16 most of its income in the tax year comprises of passive income (i.e., income from dividends, royalties, interests, rentals and/or capital gains) or most of its profits derive from passive income; the tax rate applicable to its passive income in the foreign country does not exceed 20%; more than 50% of one or more of its means of control are directly or indirectly held by Israeli residents or more than 40% of one or more of its means of control are held by Israeli residents who, together with a relative of one or more of them, hold more than 50% of one or more of its means of control or in the case where an Israeli resident has the right to prevent the adoption of substantive management decisions, including decisions with regard to dividend distributions or winding-up. Tax Avoidance Measures Israeli tax laws include, inter alia, specific anti-tax avoidance provisions (e.g., rules applicable to CFCs) and a general anti-tax avoidance rule, according to which the tax authorities may disregard certain transactions or dispositions for tax purposes. 38. List the countries in which there are tax treaties. This could impact the withholding taxes on various distributions and to the extent possible, please itemize them below. Please include the impact upon withholding on compensation, interest, dividends or other distributions for each country listed. Israel has entered into tax treaties with more than forty countries, examples of which include: the United States of America, the United Kingdom, the Netherlands, Germany, France, Japan, China, Switzerland, Turkey and many other countries. Israel has also signed tax treaties with Brazil, Croatia, Luxembourg and Ukraine but such treaties have not yet been ratified. The provisions of any tax treaty in force supersede the provisions of any legislation enacted in Israel with respect to the relevant taxation issue in question. Certain provisions of the tax treaties include tax-sparing relief intended to protect the special tax incentives given by Israel to foreign investors. In general, the various withholding tax rates on dividends, interest and royalties under the applicable tax treaties to which Israel is a party (some of such treaties were not entered into force yet but expected to do so soon), are as follows: Country Dividend (%) Interest (%) Royalties (%) Non-treaty countries Austria

17 Belarus 10 5/10 5/10 Belgium Brazil 10/15 0/15 10/15 Bulgaria / Canada People s Republic of China 10 7/10 10 Croatia 5/10/15 5/10 5 Czech Republic 5/15 0/10 5 Denmark 5/15/ Ethiopia 5/10/15 5/10 5 Finland 5/15/ France 5/10/15 5/10 10 Germany 25 0/15 5/0 Greece Hungary 15/5 0/25 0/25 India 10 0/10 10 Ireland 10 5/10 10 Italy 10/ /10 Jamaica 15/22.5 0/15 10 Japan 5/ Latvia 5/10/15 5/10 5 Luxembourg 5/10/15 5/10 5 Mexico 5/10 0/10 10 Moldova 5/ The Netherlands 5/10/15 10/15 5/10 Norway 5/15/ The Philippines 10/15 10/0 Up to 15 Poland 5/10 5 5/10 Portugal 5/10/ Romania 15 5/10 10 Russia 10 0/10 10 Singapore 5/ Slovakia 5/10 2/5/10 5 Slovenia 5/10/ South Africa /0 South Korea 5/10/15 0/7.5/10 2/5 Spain 10 5/10 5/7 Sweden 15/ Switzerland 5/10/15 0/5/10 5 Thailand 10/15 10/15 5/15 Turkey 10 0/10 10 Ukraine 5/10/15 5/10 10 United Kingdom /15 United States of America 12.5/15/25 10/ /15 Uzbekistan /10

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