Emerging Markets Rates and Currencies Handbook

50 Citi | Emerging Markets Currencies Handbook 2021 Capital Market Investments Supporting document and proof of legitimation is required for all transactions (Listed securities: broker confirmation; unlisted securities: contract of private deal, approval from relevant authorities if applicable. Additional documents may be required, subject to the nature of actual transactions). The investment needs to be performed via indirect investment capital account. Repatriation/dividend payment for direct investment The following documents must be submitted to the bank: • Board of Management Minutes on profit repatriation (BOM). • Audited Financial Report of the repatriation fiscal year. • Dividend Tax Declaration Form. Note: Payment only can be made after 7 working days since the receipt date of tax authority (including receipt date) or Tax confirmation for Tax fulfilment if we receive Tax Notification for client’s tax obligation incomplete. Citibank N.A. Ho Chi Minh City Branch Sunwah Tower, 115 Nguyen Hue Boulevard District 1, Ho Chi Minh City, Vietnam Citibank N.A. Hanoi Branch Horison Tower, 40 Cat Linh Street, Dong Da District, Hanoi, Vietnam Corporate Sales & Solutions Contact: +84 28 3521 1280 /+84 28 3521 1289 Email: citivnfx@citi.com Vietnam Item Inter-Co Debt Offshore Bank Loans Offshore Local Borrowing Derivatives Equity W/H Tax 5% WHT • Under certain tax treaties typically 10%, with further reduction possible on country-by- country basis 5% WHT • Under certain tax treaties typically 10%, with further reduction possible on country-by- country basis No WHT 2% WHT on IRS 2% WHT on CCS Bonds: • 5% WHT on coupon • 0.1% WHT on sales of bonds Equities: • 0% WHT on dividend • 0.1% WHT on sales of securities Deductibility of interests Cap on interest deduction to 30% of company’s EBITDA Fully deductible N/A N/A Deductibility of FX losses Fully deductible N/A Other taxes, duties N/A N/A N/A N/A N/A Comments Offshore loans must be in foreign currencies A foreign loan can be made in any freely convertible foreign currency Domestic loans are mostly required to be made in VND Local Vietnamese banks may also make loans in a currency other than VND in very limited circumstances N/A The WHT rates from the DTAs with Vietnam are higher, therefore those under the domestic law are applied instead Note: Citigroup Inc. and any of its affiliates do not provide accounting, tax, or legal advice. Please seek advice from a relevant licensed advisor. Source: Relevant legislation, publicly available sources. Subsidiary Funding — Tax Consideration Tax Summary — Vietnam