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Withholding Tax Rates 2014* (Rates are current as of 1 March 2014) Jurisdiction Dividends Interest Royalties Notes Afghanistan 20% 20% 20% International Tax Albania 10% 10% 10% Algeria 15% 10% 24% Andorra 0% 0% 5% Argentina 10%/35% 15.05%/35% Armenia 10% 10% 10% 12.25%/ 17.5%/21%/ 28%/31.5% Dividends subject to 10% withholding tax as from 23 September 2013, plus additional 35% withholding tax applies only if dividends exceed payer company s accumulated taxable income, after certain adjustments. Portion of gross royalties subject to tax varies depending on type of payment, and effective rates range from 12.25% to 31.5%. Aruba 0%/5%/10% 0% 0% Australia 0%/30% 10% 30% Austria 25% 0%/25% 20% Azerbaijan 10% 10% 14% Bahamas 0% 0% 0% Bahrain 0% 0% 0% Bangladesh 20% 10% 10% Barbados 0%/15%/25% 0%/15% 0%/15% Belarus 12% 10% 15% Belgium 10%/15%/25% 15%/25% 15%/25% Benin 7%/10%15% 0%/3%/6%/15% 10%/12% Bermuda 0% 0% 0% Bhutan 10% 5% 5% Bolivia 25% 25% 25% Rate levied on 50% of payment, resulting in 12.5% rate. Bosnia-Herzegovina 0%/5% 10% 10% Botswana 7.5% 15% 15% Republika Srpska does not levy withholding tax on dividends. Brazil 0% 15%/25% 15%/25% British Virgin Islands 0% 0% 0% Brunei 0% 15% 10% Bulgaria 0%/5% 10% 10% or withholding tax rate reduced Cambodia 14% 14% 14% Canada 25% 0%/25% 0%/25%

Cayman Islands 0% 0% 0% Chile 35% 4%/35% 15%/30% China 10% 10% 10% Colombia 33% 0%/14%/33% 33% Withholding tax on royalties for licensing software levied on 80% of payment. Congo (Dem. Rep.) 20% 20% 20% Cook Islands 15% 15% 15% Costa Rica 5%/15% 0%/15% 25% Croatia 12% 15%/20% 15%/20% or withholding tax reduced Curaçao 0% 35% 0% Cyprus 0% 0% 5%/10% or withholding tax reduced Czech Republic 15%/35% 15%/35% 15%/35% Denmark 0%/15%/27% 0%/25% 25% Rate increases to 35% if payment made to tax haven. or withholding tax reduced Dominican Republic 10% 10% 28% Rate on royalties reduced from 29% on 1 January 2014. Ecuador 0%/13% 0%/22% 22% Egypt 0% 0%/20% 20% El Salvador 5%/25% 20%/25% 20%/25% Rate increases to 25% if payment made to tax haven. Equatorial Guinea 25% 25% 10% Estonia 0% 0% 10% Fiji 0%/15% 10% 15% Finland 20% 0% 20% France 30%/75% 0%/75% 33.33%/75% As from 1 January 2014, withholding tax on interest applies only where nonresident investor derives interest income from Estonian contractual fund or other pools of assets. Qualifying payments to EU companies may be exempt Rate on dividends and interest reduced from 24.5% for financial years ending on or after 1 January 2014. Rate increases to 75% for payments made to companies located in noncooperative countries. Georgia 5% 5%/15% 10%/15% Rate increases to 15% for payments made to tax haven. Germany 25% 0% 15% Gibraltar 0% 0% 0% Greece 10%/25% 15% 20% Rates on interest and royalties reduced from 33% and 25%, respectively, as from 1 January 2014. Guam 0%/30% 0%/30% 30% Guatemala 5% 0%/10% 15%

Guernsey 0% 0% 0% Guyana 20% 20% 20% Honduras 10% 10% 25% Hong Kong SAR 0% 0% 4.95%/16.5% Hungary 0% 0% 0% Iceland 0%/18% 10% 20% India 0% 5%/20% 25% Indonesia 20% 20% 20% Iraq 0% 15% 0% Ireland 0%/20% 20% 20% Isle of Man 0% 0% 0% Israel 4%/15%/20%/ 25%/30% 0%/15%/25% 25% Italy 1.375%/20% 12.5%/20% 30% Ivory Coast 10%/12%/18% 6%/15%/18%/ 25% 20% Jamaica 33.33% 33.33% 33.33% Royalties taxed on 75% of gross payment, resulting in effective rate of 22.5%. Qualifying payments to EU companies may be exempt Japan 20% 15%/20% 20% Jersey 0% 0% 0%/20% Jordan 0% 7% 7% Kazakhstan 15%/20% 15%/20% 15%/20% Rate of 20% applies when payment made to nonresident registered in tax haven. Kenya 0%/5%/10% 10%/15%/25% 20% Korea (ROK) 20% 15.4%/20% 20% Kuwait 0%/15% 0% 0% Kyrgyzstan 10% 10% 10% Laos 10% 10% 5% Latvia 0% 0% 0% Only payments to residents of black list jurisdictions are subject to withholding tax. Rates are 15% on dividends, 30% on interim dividends, 5% on interest paid by banks, 15% on all other interest and 15% on royalties. Lebanon 10% 5%/10% 7.5% Libya 0% 0%/5% 0% Liechtenstein 0% 0% 0% Lithuania 0%/15% 0%/10% 10% Luxembourg 0%/15% 0% 0% or withholding tax rate reduced Qualifying payments to corporation subject to tax in treaty country may be exempt. Macao SAR 0% 0% 0% (FYROM) Macedonia 10% 10% 10% Madagascar 0% 20% 10%

Madeira 25%/35% 25%/35% 25% 35% rate applies to dividends and interest payments made to resident of listed tax haven. Malawi 10% 15% 15% Malaysia 0% 15% 10% Maldives 0% 0% 10% Malta 0% 0% 0% Marshall Islands 0% 0% 0% Mauritius 0% 15% 0%/15% Mexico 10% 4.9%/10%/15%/ 21%/30%/40% 25%/30%/ 40% Withholding tax of 10% applies to dividends paid out of profits generated after 1 January 2014. Moldova 6% 12% 12% Monaco 0% 0% 0% Montenegro 9% 9% 9% Morocco 15% 10% 10% Mozambique 10%/20% 20% 20% Namibia 10%/25% 10% 9.9% Nauru 0% 0% 0.0% Nepal 5% 15% 15% Netherlands 0%/15% 0% 0% New Zealand 15%/30% 15% 15% Nigeria 10% 10% 10% Norway 0%/25% 0% 0% No tax withheld on dividends paid to corporate shareholders resident in EEA. Oman 0% 0% 10% Palau 0% 0% 0% Palestinian Territories 0% 5% 5% Panama 5%/10%/20% 12.5% 12.5% Papua New Guinea 0%/10%/17% 15% 10%/30% Paraguay 15% 30% 30% Withholding tax on interest and royalties levied on 50% of payment, so effective rate is 15%. Peru 4.1% 4.99%/30% 30% Philippines 15%/30% 20% 30% Poland 19% 20% 20% or withholding tax rate reduced

Portugal 25%/35% 25%/35% 25% Puerto Rico 10% 29% 29% Qatar 0% 7% 5% 35% rate applies to dividends and interest payments made to resident of listed tax haven. Qualifying payments to EU companies may be exempt or withholding tax rate reduced Romania 16% 16% 16% or withholding tax rate reduced Russia 15% 20% 20% Saudi Arabia 5% 5% 15% Senegal 10% 8%/16%/20% 20% Serbia 20%/25% 20%/25% 20%/25% Rate increases to 25% for payments made to resident in preferential tax jurisdiction. Singapore 0% 15% 10% Slovakia 0% 19%/35% 19%/35% Slovenia 15% 15% 15% Solomon Islands 30% 0%/10% 15% South Africa 15% 0% 12% 35% rate applies to interest and royalties payments made to resident of listed tax haven. Qualifying payments to EU companies may be exempt under EU directives. A 15% interest withholding tax will be introduced as from 1 January 2015. South Sudan 10% 10% 10% Spain 21% 21% 24.75% or withholding tax rate reduced Sri Lanka 10% 15% 15% St. Kitts & Nevis 10% 10% 10% St. Lucia 25% 25% 25% St. Maarten 0% 35% 0% Swaziland 15% 10% 15% Sweden 0%/30% 0% 0% Switzerland 35% 0%/35% 0% or withholding tax rate reduced Under Switzerland's agreement with EU, measures equivalent to EU parent-subsidiary directive apply in qualifying cases. Syria 0% 7.5% 5% Taiwan 20% 15%/20% 20% Tajikistan 12% 12% 12% Tanzania 5%/10% 0%/10% 15% Thailand 10% 15% 15% Trinidad & Tobago 5%/10% 15% 15%

Tunisia 10% 5%/20% 15% As from 1 January 2014, 10% withholding tax levied on dividends paid to nonresident company and 15% withholding tax levied on royalties. Turkey 15% 0%/10% 20% Turkmenistan 15% 15% 15% Turks & Caicos 0% 0% 0% Uganda 15% 15%/20% 15% Ukraine 15% 15% 15% United Arab Emirates 0% 0% 0% United Kingdom 0% 20% 20% United States 30% 30% 30% Uruguay 7% 3%/5%/12% 12% Uzbekistan 10% 10% 20% Vanuatu 0% 0% 0% Venezuela 0%/34% 4.95%/15%-34% 34% Withholding tax levied on 95% of gross interest (at 15%- 34% rates) and 90% of gross royalties, giving rise to effective rates of 14.7%-32.3% and 30.6%, respectively. Vietnam 0% 5% 10% Wallis & Fortuna 0% 0% 0% Yemen 10% 0%/10% 10% Zambia 15% 15% 20% Zimbabwe 10%/15% 0% 15% * Rates apply to payments to nonresidents and may be reduced under provisions of applicable tax treaty. Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited, a UK private company limited by guarantee ( DTTL ), its network of member firms, and their related entities. DTTL and each of its member firms are legally separate and independent entities. DTTL (also referred to as Deloitte Global ) does not provide services to clients. Please see www.deloitte.com/about for a more detailed description of DTTL and its member firms.deloitte provides audit, tax, consulting, and financial advisory services to public and private clients spanning multiple industries. With a globally connected network of member firms in more than 150 countries and territories, Deloitte brings world-class capabilities and high-quality service to clients, delivering the insights they need to address their most complex business challenges. Deloitte s more than 200,000 professionals are committed to becoming the standard of excellence. Deloitte provides audit, tax, consulting, and financial advisory services to public and private clients spanning multiple industries. With a globally connected network of member firms in more than 150 countries and territories, Deloitte brings world-class capabilities and highquality service to clients, delivering the insights they need to address their most complex business challenges. Deloitte s more than 200,000 professionals are committed to becoming the standard of excellence. This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms, or their related entities (collectively, the Deloitte network ) is, by means of this communication, rendering professional advice or services. No entity in the Deloitte network shall be responsible for any loss whatsoever sustained by any person who relies on this communication. 2014. For information, contact Deloitte Touche Tohmatsu Limited.