Estonia: Withholding tax procedures

Transcription

1 Announcement Custody A051 Estonia: Withholding tax procedures Clearstream Banking 1 is pleased to announce details of the withholding tax procedures applicable to Estonian securities held in Clearstream Banking. Income payments on Estonian debt securities and equities are subject to withholding tax at a standard rate of 26%. Estonian domestic law provides for full relief (exemption) at source from withholding tax for eligible beneficial owners on certain types of income payment. Partial relief at source is available to nonresident beneficial owners entitled to the benefit of a Double Taxation Treaty (DTT) between Estonia and the beneficial owner's country of residence. If relief at source (full or partial) has not been obtained by a beneficial owner who is eligible for relief, a reclaim of withholding tax is available. Estonian Debt securities Relief at source Full relief (exemption) at source Under Estonian domestic law, the following beneficial owners are entitled to exemption at source from withholding tax on certain interest payments: Estonian corporations: - for interest payments on all Estonian debt securities; Individuals resident in Estonia: - for interest payments on debt securities issued by Estonian credit institutions or by the Compensation Fund; and - for interest payments on debt securities issued by branches located and registered in Estonia of non-resident credit institutions; Individuals non-resident in Estonia: - for interest payments on debt securities issued by Estonian credit institutions or by the Compensation Fund; Credit or financial institutions that are non-residents of Estonia: - for interest payments on debt securities issued by the Republic of Estonia, a local government or a resident corporation, if the interest payments are subject to an income tax rate that is not less than 2/3 of the income tax applicable in Estonia, i.e. 17.3%. Partial relief at source Partial relief at source is available if the beneficial owner qualifies for the benefit of a reduced rate of withholding tax in accordance with the DTT between the beneficial owner's country of residence and Estonia (See Appendix 1 on page 4). Tax Reclaim A reclaim of withholding tax is available if relief at source (either full or partial) has not been obtained by a beneficial owner eligible for such relief. The customer can reclaim the withholding tax on behalf of the beneficial owner through Clearstream Banking by submitting the appropriate documentation. 1. Clearstream Banking in this document refers collectively to Clearstream Banking Frankfurt (CBF) and Clearstream Banking Luxembourg (CBL). Clearstream Banking is a Deutsche Börse Group company. A051 (1)

2 Estonian equities Relief at source Full relief (exemption) at source Under Estonian domestic law, exemption at source on dividend payments on Estonian equities is available for the following beneficial owners: All Estonian residents (individuals and corporations); Corporations that are not resident in Estonia if they hold more than 25% of the share capital of the company paying the dividend and are not resident in a low tax rate territory (see Appendix 3 on page 6). Partial relief at source Partial relief at source is available if the beneficial owner qualifies for the benefit of a reduced rate of withholding tax in accordance with the DTT between the beneficial owner's country of residence and Estonia (see Appendix 2 on page 5). Tax Reclaim A reclaim of withholding tax is available if relief at source (either full or partial) has not been obtained by a beneficial owner eligible for such relief. The customer can reclaim withholding tax on behalf of the beneficial owner through Clearstream Banking by submitting the appropriate documentation. Certification requirements Important note: For the following types of beneficial owner, specific requirements apply instead of the certification requirements that apply in the general procedures for the relief at source and for the refund of withholding tax, as explained below: Estonian individuals must submit a copy of their passport instead of the requested Certificate of Residence due to the fact that the Estonian Tax Authorities do not issue a Certificate of Residence to private individuals; Non-resident credit or financial institutions eligible for exemption under Estonian domestic law must submit information provided by their local tax authorities on the rate of income tax applicable in their country of residence as well as certification of their status as a credit or financial institution (unless a copy of their license is attached). This information can be added to the Certificate of Residence. Non-resident individuals who are eligible for exemption under Estonian domestic law must submit copies of their passports in order to certify their status as private individuals. Relief at source In order to benefit from relief at source from withholding tax on interest or dividends, customers must provide Clearstream Banking with the following documents: If the customer is the sole beneficial owner: - A Certification for Estonian Withholding Tax Purposes (Appendix 4 on page 8); and - A Certificate of Residence, valid for one year from the date of issue by the tax authorities of the beneficial owner s country of residence (see Appendix 6 on page 13). If the customer is not the sole beneficial owner: - A Certification for Estonian Withholding Tax Purposes (Appendix 4 on page 8); and - A Declaration of Beneficial Ownership (see Appendix 5 on page 10); and - A Certificate of Residence for each beneficial owner that is valid for one year from the date of issue by the tax authorities of the country of residence of the beneficial owner (see Appendix 6 on page 13). A051 (2)

3 These documents must be received by Clearstream Banking by 10:00 CET not later than 20 business days prior to the payment date. Tax Reclaim In order to benefit from a refund of tax withheld on interest or dividends, the Clearstream Banking customer must provide Clearstream Banking with the following documents: A Letter of Request to Clearstream Banking for a Tax Refund (see Appendix 7 on page 14); A Certificate of Residence, issued by the tax authorities of the country of residence of the beneficial owner no earlier than one year prior to the relevant income payment (see Appendix 6 on page 13); A Power of Attorney in favour of Clearstream Banking to allow Clearstream Banking to act as its legal representative (see Appendix 8 on page 16); and A Credit Advice (see Appendix 9 on page 17). These documents must be received by Clearstream Banking at the latest two months before the statutory deadline. Statutory deadline The statutory deadline for reclaiming withholding tax is three years after the payment date. The deadline by which Clearstream Banking must receive the documentation for an application is at the latest two months prior to the statutory deadline. All refund applications received after this deadline will be processed by Clearstream Banking on a best-efforts basis. However, in such cases, Clearstream Banking will apply an extra charge and accepts no responsibility for forms that have not reached the Estonian Tax Authorities by the date considered being the statute of limitations deadline. With respect to tax refunds in general, customers are reminded that Clearstream Banking accepts no responsibility for their acceptance or non-acceptance by the tax authorities of the respective country. It is the customer's responsibility to determine any entitlement to a refund of tax withheld, to complete the forms required correctly and to calculate the amount due. Further information The Clearstream Banking Customer Tax Guide, which is available on the Clearstream Banking web site ( will be updated to reflect these changes in due course. For further information, please contact Clearstream Banking Tax Help Desk or your Customer Relationship Manager. A051 (3)

4 Appendix 1. Debt securities - Double Taxation Treaties concluded by Estonia and currently in force Note: There is currently no prescribed form for tax refund available for use. Country Rate Prescribed by the DTT - Interest (%) Tax Refund Available (%) Prescribed Form for Tax Refund The standard rate of withholding tax on interest is 26% prior to any refund. Belarus Canada China Czech Republic Denmark Finland France Germany Iceland Ireland Italy Kazakhstan Latvia Lithuania Moldova Netherlands Norway Poland Sweden Ukraine United Kingdom United States A051 (4)

5 Appendix 2. Equities - Double Taxation Treaties concluded by Estonia and currently in force Note: The rate as prescribed in the DTT assumes that the beneficial owner does not hold a substantial percentage of the share capital of the company paying the dividend. Different rates may apply for substantial holdings. Please refer to the actual DTT or your tax advisor for further information. There is currently no prescribed form for tax refund available for use. Country Rate Prescribed by the DTT - Dividends (%) Tax Refund Available (%) Prescribed Form for Tax Refund The standard rate of withholding tax on dividends is 26% prior to any refund. Belarus Canada China Czech Republic Denmark Finland France Germany Iceland Ireland Italy Kazakhstan Latvia Lithuania Moldova Netherlands Norway Poland Sweden Ukraine United Kingdom United States A051 (5)

6 Appendix 3. Low tax rate territories Name in English Name in Estonian if it differs from the name in English Name in English Name in Estonian if it differs from the name in English Andorra Lebanon Liibanon Anguilla Antigua & Barbuda Aruba Bahamas (including...) - Abaco - Eleuthera Bahama saared (sealhulgas...) Liberia Liechtenstein Luxembourg Macau Bahrain Bahrein Macedonia Barbados Madeira Belize Maldives Maldiivid Bermuda Malta Cayman Islands (including...) - Cayman Brac - Grand Cayman Kaimanisaared (sealhulgas...) Marshall Islands (including...) Kwajalein Marshalli Saared (sealhulgas...) Channel Islands (including..) - Alderney - Guernsey - Jersey - Sark Kanalisaared (sealhulgas...) Mauritius Chile Tsiili Monaco Cook Islands Cooki saared Montserrat Costa Rica Nauru Cyprus Küpros Netherlands Antilles Hollandi Antillid Djibouti New Caledonia Uus-Kaledoonia Dominican Republic Dominikaani Vabariik Niue French Polynesia (including...) - Bora Bora - Tahiti Prantsuse Polüneesia (sealhulgas...) Oman Omaan Gibraltar Palau Grenada Panama Guam Guam Puerto Rico Guatemala Qatar Hong Kong Hongkong Saint Cristopher and Nevis / Saint Kitts and Nevis Saint Kitts ja Nevis Isle of Man Man saar Saint Helena Jamaica Saint Vincent and The Grenadines Saint Vincent ja Grenadiinid Kenya Keenia San Marino Kuwait Kuveit San Marino Labuan Seychelles Seisellid A051 (6)

7 Appendix 3 (cont). Low tax rate territories Name in English Name in Estonian if it differs from the name in English Name in English Name in Estonian if it differs from the name in English Singapore Singapur Vanuatu Switzerland Sveits Venezuela Venetsueela Trinidad and Tobago Trinidad ja Tobago Vietnam Turks and Caicos Islands Turksi ja Caicose Saared Virgin Islands UK (including...) - Tortola Briti Neitsisaared (sealhulgas...) United Arab Emirates (including...) - Dubai Araabia Ühendemiraadid (sealhulgas...) Virgin Islands US (including...) - Saint Croix Ühendriikide Neitsisaared (sealhulgas...) Uruguay Western Samoa Lääne Samoa A051 (7)

8 Appendix 4. Certification for Estonian Withholding Tax Purposes [Customer s letterhead] Clearstream Banking ATT: Department CID Neue Börsenstrasse 1 D Frankfurt am Main Germany Date: Subject: Certification for Estonian Withholding Tax Purposes Account: Dear Sir/Madam, The undersigned customer of Clearstream Banking may hold from time to time in its securities account (the account ) with Clearstream Banking, Luxembourg securities issued by entities organised under the laws of Estonia (the securities ). For the purpose of ensuring that relief at source is granted from Estonian withholding tax on certain income payments, we hereby certify that (check (ü) box 1 or box 2 but not both and check and complete the appropriate box(es)): c 1. We are the beneficial owner of any such securities we may hold from time to time in the account. c c c c (continued on next page) We are a corporate, resident of Estonia and are entitled to an exemption from withholding tax on income payments made on all Estonian securities. We are a non-resident credit or financial institution and are entitled to an exemption from withholding tax on interest payments on Estonian debt securities issued by the Republic of Estonia, a local government or a Estonian corporation as the interest payments are subject to an income tax rate in our country of residence which is not less than two-thirds of the income tax rate applicable in Estonia, i.e. 17.3%. We are a corporation, non-resident of Estonia or of a low tax rate territory, and are entitled to an exemption from withholding tax on income payments on Estonian equities as we hold more than 25% of the share capital of the company paying the dividend. We are resident for tax purposes in and are entitled to application of withholding tax at reduced rate of according to the Double Taxation Treaty concluded between Estonia and our Country of residence. We hereby undertake to provide Clearstream Banking with a new Certification for Estonian Withholding Tax Purposes, a list of beneficial owners entitled to tax relief and a statement of the securities not entitled to relief in the relevant form (see Declaration of Beneficial Ownership) if, on any record date in Estonia, we hold any such securities on behalf of a third party beneficial owner. c 2. We are not the beneficial owner of all securities we may hold from time to time in the above-mentioned account. We hereby undertake to provide Clearstream Banking with a list of beneficial owners entitled to tax relief and a statement of the securities not entitled to relief in the relevant form (see Declaration of Beneficial Ownership), for each relevant interest or dividend payment date. The list of beneficial owners provided for one interest or dividend payment date shall be valid for any subsequent interest or dividend payment dates as long as we have not provided Clearstream Banking with a new list of beneficial owners within the established deadlines for a relevant interest or dividend payment date and as long as our holding of the relevant security has not changed. We hereby undertake to provide Clearstream Banking with such a new list of beneficial owners entitled to tax relief and a statement of the securities not entitled to relief in the relevant form (see Declaration of Beneficial Ownership) if, by any record date in Estonia, there has been a change of the beneficial ownership since the previous interest or dividend payment date. A051 (8)

9 Appendix 4 (cont d). Certification for Estonian Withholding Tax Purposes (continued from previous page) We hereby appoint irrevocably Clearstream Banking and the Clearstream Banking Depository as our attorney-in-fact with the authority to collect and submit to the competent Estonian authorities, including the Estonian tax authorities, this certificate or a copy hereof and any document submitted to Clearstream Banking pursuant to this certificate as well as the balances of Estonian securities in our accounts, in connection with any administrative or legal proceedings or official inquiries for which this certificate is or would be relevant. We hereby accept full responsibility in case of any claims made for additional taxes, interest thereon, or penalties levied by tax authorities in connection with any payments made subject to this certificate or the list of beneficial owners. We indemnify Clearstream Banking in respect of any penalties, taxes and interest thereon, levied by the Estonian Tax Authorities or any other authority, and in respect of any other costs incurred in connection with any action taken in reliance upon the contents of this Certification for Estonian Withholding Tax Purposes. We understand that, in order to obtain any income payment with respect to the securities either subject to withholding tax at a reduced rate or exempt from withholding tax according to a Double Taxation Treaty concluded with the Estonia, it may be necessary for Clearstream Banking to supply certain information to the Clearstream Banking Depository in Estonia, to the issuer of the securities and to the Estonian tax authorities. We understand that the Estonian authorities may forward the information received from us in connection with this procedure to the tax authorities of the countries of residence of the beneficial owners. We hereby undertake to notify Clearstream Banking promptly upon receipt of any information that would render any statement in this certificate, including any list of beneficial owners entitled to tax relief and a statement of the securities not entitled to relief (see Declaration of Beneficial Ownership), untrue or incomplete. For and behalf of: Name of Clearstream Banking customer: Address of Clearstream Banking customer: Residence for tax purposes: By (authorised signatories): Signature: Name (Print): Title: Tax address and Tax ID: (if applicable, full address) Date: Signature: Name (Print): Title: Tax address and Tax ID: (if applicable, full address) Date: A051 (9)

10 Appendix 5. Declaration of Beneficial Ownership [Customer s letterhead] (This declaration can be returned by mail, tested telex, or authenticated SWIFT and is to be received by Clearstream Banking no later than one business day prior to the record date of the income payment.) Clearstream Banking ATT: Department CID Neue Börsenstrasse 1 D Frankfurt am Main Germany Subject: Declaration of Beneficial Ownership for Relief from Estonian Withholding Tax on Estonian Securities This declaration amends our Certification for Estonian Withholding Tax Purposes dated, which otherwise remains valid and correct. We certify that we hold in our Clearstream Banking, Luxembourg account, the following quantities of the following securities for the beneficial owners listed below and that we are authorised to collect the income payments due on. This declaration applies to the following positions: A. The beneficial owner is a corporation resident of Estonia and eligible for exemption from Estonian withholding tax. Name, tax address and tax ID of beneficial owner Common code or ISIN Quantity of securities B. The beneficial owner is an Estonian resident individual and eligible for exemption from Estonian withholding tax on Estonian equities and on Estonian debt securities issued by Estonian credit institutions, the Compensation Fund or branches of non-resident credit institutions registered in Estonia. Name, tax address and tax ID of beneficial owner Common code or ISIN Quantity of securities C. The beneficial owner is an individual non-resident of Estonia and eligible for exemption from Estonian withholding tax on Estonian debt securities issued by Estonian credit institutions or the Compensation Fund. Name, tax address and tax ID of beneficial owner Common code or ISIN Quantity of securities (continued on next page) A051 (10)

11 Appendix 5 (cont d). Declaration of Beneficial Ownership (continued from previous page) D. The beneficial owner is a non-resident credit or financial institution and eligible for exemption from Estonian withholding tax on interest on Estonian debt securities issued by the Republic of Estonia, a local government or an Estonian corporation; the interest payments are subject to an income tax rate in the beneficial owner s country of residence which is not less than two-thirds of the income tax applicable in Estonia, i.e. 17.3%. Name, tax address and tax ID of beneficial owner Common code or ISIN Quantity of securities E. The beneficial owner is a corporation that is not resident in Estonia or in a low tax rate territory and is eligible for exemption from Estonian withholding tax on Estonian equities as the beneficial owner holds more than 25% of the share capital of the company paying the dividend. Name, tax address and tax ID of beneficial owner Common code or ISIN Quantity of securities F. The beneficial owner is entitled to the benefit of the DTT between its country of residence and Estonia and is eligible for partial relief from Estonian withholding tax. Name, tax address and tax ID of beneficial owner Reduced rate of withholding tax Common code or ISIN Quantity of securities G. The beneficial owner is not entitled to relief at source from Estonian withholding tax. Name, tax address and tax ID of beneficial owner Common code or ISIN Quantity of securities Yours faithfully, (continued on next page) A051 (11)

12 Appendix 5 (cont d). Declaration of Beneficial Ownership (continued from previous page) Authorised signatories: Signature: Signature: Name (Print): Name (Print): Title: Title: Date: Date: Company stamp: A051 (12)

13 Appendix 6. Certificate of Residence Date: Attention: Subject: Certificate of Residence Dear Sir/Madam: We confirm that, Tax ID number is resident in for the purpose of the Double Taxation Treaty between Estonia and and that, to the best of our knowledge and information, the above information is correct. Accordingly, qualifies for benefit from the Double Taxation Treaty between Estonia and. Yours faithfully, A051 (13)

14 Appendix 7. Letter of Request for Reclaim to Clearstream Banking [Customer s letterhead] Clearstream Banking ATT: Department CID Neue Börsenstrasse 1 D Frankfurt am Main Germany Date: Subject: Certification for Estonian Withholding Tax Purposes Account: Dear Sir/Madam: We refer to the following income payment on the following security: Type of security (share, bond): Issuer of the security: Security code (ISIN or Common Code): Income payment date: Our Clearstream Banking, Luxembourg account, number, was credited with the above income payment under deduction of 26% Estonian withholding tax, on the following quantity of securities beneficially owned by the following beneficial owner: Name of beneficial owner: Residence of beneficial owner (full address): Tax ID number of the beneficial owner: Quantity of securities: Total dividend or interest amount received, net of withholding tax: Please tick one of the following boxes: c 1. We hereby request that Clearstream Banking, Luxembourg forward our application to the Estonian Tax Authorities for a refund of withholding tax, to which the beneficial owner is entitled by virtue of the Double Taxation Treaty between Estonia. c 2. We hereby request that Clearstream Banking, Luxembourg forward our application to the Estonian Tax Authorities for a refund of withholding tax, to which beneficial owner, a corporation resident in Estonia is entitled by virtue of the Estonian domestic legislation. c 3. We hereby request that Clearstream Banking, Luxembourg forward our application to the Estonian Tax Authorities for a refund of withholding tax, withheld on Estonian securities issued by Estonian credit institutions, the Compensation Fund or branches of non-resident credit institutions registered in Estonia, to which the beneficial owner, a resident individual resident in Estonia is entitled by virtue of the Estonian domestic legislation. A051 (14)

15 Appendix 7 (cont d). Letter of Request for Reclaim to Clearstream Banking c 4. We hereby request that Clearstream Banking, Luxembourg forward our application to the Estonian Tax Authorities for a refund of withholding tax, withheld on Estonian debt securities issued by Estonian credit institutions or the Compensation Fund, to which the beneficial owner, an individual non-resident in Estonia is entitled by virtue of the Estonian domestic legislation. c 5. We hereby request that Clearstream Banking, Luxembourg forward our application to the Estonian Tax Authorities for a refund of withholding tax, withheld on Estonian debt securities issued by the Republic of Estonia, a local government or an Estonian corporation as the interest payments are subject to an income tax rate with is not less than two-thirds of the income tax applicable in Estonia, i.e. 17.3%, to which the beneficial owner, a credit or financial institution that is non-resident of Estonia is entitled by virtue of the Estonian domestic legislation c 6. We hereby request that Clearstream Banking, Luxembourg forward our application to the Estonian Tax Authorities for a refund of withholding tax, withheld on Estonian equities to which the beneficial owner, a corporation that is neither a resident of Estonia nor a resident of a low tax rate territory, is entitled by virtue of the Estonian domestic legislation, as the beneficial owner holds more than 25% of the share capital of the company paying the dividend. Please credit the withholding tax refunded to the above Clearstream Banking, Luxembourg account, with reference, upon request from the Estonian Tax Authorities. Yours faithfully, By (authorised signatories): Signature: Name (Print): Title: Date: Signature: Name (Print): Title: Date: A051 (15)

16 Appendix 8. Power of Attorney Date: [Beneficial owner s letterhead] Subject: Power of Attorney I/we, the undersigned, of, make, constitute and appoint CBL, my (our) true and lawful attorney-in-fact in my (our) name, place and stead, on my (our) behalf, and for my (our) use and benefit, to exercise or perform any act, power or duty, right or obligation whatsoever that I (we) now have, or may subsequently acquire with respect to the reclaim of tax withheld on investment income in respect of debt and equity securities. The rights, powers, and authority of attorney-in-fact granted shall commence and be in full force and effect immediately upon the execution of this instrument. Such rights, powers and authority shall remain in force and effect thereafter until revoked by me (us) in writing. Authorised signatories: Signature: Signature: Name (Print): Name (Print): Title: Title: Date: Date: Company stamp: A051 (16)

17 Appendix 9. Credit Advice The following credit advice is an example of the format currently used at Clearstream Banking. This credit advice contains information that is required when filing a request for refund of withholding tax. The information in the credit advice may differ depending on the financial institution paying the beneficial owner. NAME: TOWN DUE DATE SECURITY CODE EX: CPN ACCOUNT NUMBER NOMINAL AMOUNT SECURITY IDENTIFICATION RATE% GROSS AMOUNT 1 TAX% AMOUNT TAXES AMOUNT AFTER TAXES FIXED RATE GROSS AMOUNT CONVERSION RATE NET FEES% AMOUNT FEES AMOUNT VALUE DATE A051 (17)

18 Announcement Tax A003 4 January 2007 Estonia: New standard rate of withholding tax on income payments Clearstream Banking 1 is pleased to inform customers that, effective 1 January 2007 the standard rate of withholding tax applicable for interest and dividend payments on Estonian securities is reduced from 23% to 22%. Estonia has a long-term program to reduce withholding tax rates to 20% by Double Taxation Treaties Additionally, Double Taxation Treaties signed between Estonia and the following countries are effective as of 1 January 2007: Country Rate prescribed in the DTT - Interest (%) Tax refund available (%) Rate prescribed in the DTT - Dividend (%) Tax refund available (%) Slovak Republic Slovenia Further information The Customer Tax Guide (Estonia), available at under Publications & Downloads / Tax Information, will be updated to reflect these changes in due course. For further information, please contact the Clearstream Banking Tax Help Desk on: Luxembourg Frankfurt tax@clearstream.com tax@clearstream.com Telephone: (0) Fax: (0) or Clearstream Banking Customer Service or your Relationship Officer. For more general information regarding Clearstream Banking products and services, please visit the Clearstream Banking web site at 1. Clearstream Banking in this Announcement refers collectively to Clearstream Banking Frankfurt (CBF) and Clearstream Banking Luxembourg (CBL). CBF and CBL are Deutsche Börse Group companies. 4 January 2007 A003 (1)

19 Announcement Tax A June 2008 Estonia: Singapore no longer regarded as low-tax jurisdiction Background Effective retroactively, as of 1 January 2008, the Government of Estonia has removed Singapore from its list of low-tax jurisdiction countries. A low-tax jurisdiction (see below) is a foreign state or territory that has an independent tax jurisdiction that does not impose tax either on profits earned or distributed by a legal person or where such tax is less than two-thirds of the income tax that an Estonian resident individual would have to pay on a similar amount of business income. The removal of Singapore from this list follows the coming into effect of the Double Taxation Treaty (DTT) between Singapore and Estonia on 1 January Note: The DTT between Georgia and Estonia also became effective on 1 January Standard rate of withholding tax: 21% Impact on customers Customers holding Estonian securities on behalf of beneficial owners - including themselves, if applicable - that are residents of Georgia or Singapore can apply for relief of tax on payments made as of 1 January 2008 through the tax procedures explained in our Customer Tax Guide (Estonia). Low tax rate territories Further information Rate prescribed in the DTT - Interest (%) Tax refund available (%) Rate prescribed in the DTT - Dividend (%) Tax refund available (%) Georgia Singapore Anguilla Dominican Republic Labuan Puerto Rico Antigua & Barbuda French Polynesia Lebanon Qatar Aruba Gibraltar Liechtenstein Saint Vincent Bahamas Grenada Macau Seychelles Bahrain Guam Macedonia Turks and Caicos Islands Barbados Guatemala Maldives United Arab Emirates Belize Guernsey (Channel Islands) Mauritius Uruguay Bermuda Hong Kong Monaco Vanuatu Brunei Isle of Man Netherlands Antilles Venezuela Cayman Islands Jamaica Nevis Vietnam Chile Jersey (Channel Islands) Niue Virgin Islands UK Costa Rica Kenya Oman Virgin Islands U.S. Djibouti Kuwait Panama Western Samoa The Customer Tax Guide (Estonia), available at under Publications & Downloads / Tax Information, will be updated to reflect these changes in due course. For further information, please contact our Tax Help Desk: Luxembourg Frankfurt tax@clearstream.com tax@clearstream.com Telephone: (0) Fax: (0) or Clearstream Banking Customer Service or your Relationship Officer. For more general information regarding our products and services, please visit 12 June 2008 A08094 (1)

20 Announcement Tax A December 2008 Estonia: Abolition of the withholding tax on dividend payments Effective Background 1 January 2009 non-resident legal entities will receive dividend payments made on Estonian equities with no deduction of withholding tax. Two laws regarding amendments to the Income Tax Act were published in the State Gazette No 51 on 9 December The principal changes are as follows: The withholding tax on dividends for non-resident legal entities will be abolished as of 1 January 2009; and The current standard withholding tax rate of 21% will remain unchanged for It is also confirmed that the rate will be reduced gradually from 20% in 2010 to 18% in Impact on customers If you hold Estonian equities on behalf of beneficial owners that are legal entities not resident in Estonia, you will receive dividend payments gross. It is not yet confirmed whether specific tax certification will be required to prove eligibility for tax exemption. We continue to monitor the Estonia market for further details on these changes and we will inform you as soon as we have any clarification on the certification requirements, if any. Note: For beneficial owners that are Estonian residents or non-resident individuals, the tax procedures as explained in our Tax Guide (Estonia) remain unchanged. Further information For further information, please contact our Tax Help Desk: Luxembourg Frankfurt tax@clearstream.com tax@clearstream.com Telephone: (0) Fax: (0) or Clearstream Banking Customer Service or your Relationship Officer. For more general information regarding our products and services, please visit 19 December 2008 A08238 (1)

21 Announcement Tax A December 2008 Estonia: No certification requirements for dividend payments Following our Announcement A08238 dated 19 December 2008 and with confirmation from our local custodian, we can inform you that, effective 1 January 2009 all dividend payments for Estonian equities will be made with no deduction of withholding tax and without any tax certification requirements. Impact on customers If you hold Estonian equities, you will receive dividend payments gross, regardless of the status and residency of the final beneficial owners. No further action is required from you in order to obtain gross dividend payments. Further information For further information, please contact our Tax Help Desk: Luxembourg Frankfurt tax@clearstream.com tax@clearstream.com Telephone: (0) Fax: (0) or Clearstream Banking Customer Service or your Relationship Officer. For more general information regarding our products and services, please visit 31 December 2008 A08244 (1)