Emerging Markets Rates and Currencies Handbook

66 Citi | Emerging Markets Currencies Handbook 2021 Item Inter-Co Debt Offshore Bank Loans Offshore Local Borrowing Derivatives Equity W/H Tax 35% WHT general rate • Under certain tax treaties rate is typically 10-20% 15.05% WHT if lender is a “Basel bank” 35% WHT for tax-haven lender No WHT N/A N/A Deductibility of interests Fully deductible if W/H tax is 35% Interest is deductible, unless D/E > 2x if W/H tax < 35% Interest is deductible, unless D/E > 2x Fully deductible N/A N/A Deductibility of FX losses Fully deductible “Hedging derivative” — Yes “Speculative derivatives” — Only against gains from other speculative derivatives N/A Other taxes, duties 21% VAT (as applicable) 0.60% charge on any debit or credit to ARS account 21% VAT (if local activity is subject to VAT); 10.50% VAT if lender is a “Basel bank” 0.60% charge on any debit or credit to ARS account (initial disbursement exempted if lender is a Basel Bank) 10.5% VAT (if local activity is subject to VAT), 21% all other 0.60% charge on any debit or credit to ARS account (initial credit of ARS into banking account is exempted) City of BA Stamp Tax: 1.2% per year capped at 1.0% on the value of the contract City of BA Stamp Tax: • 1% on the value of the contract • Exemption if there is no confirmation signed by both parties. In that case, customer sends “written offer” to Bank and Bank accepts by charging an “acceptance fee” Net worth tax applies at the rate of 0.5% on the book value If dividends are paid on an accounting income higher than the taxable income, the difference is taxed at 35% 0.60% charge on any debit or credit to ARS account Comments N/A N/A LLL 1: combination of one time (1.x) of the company’s Net Worth (NW) of the latest financial statements available plus the lesser of two times (2.x) the company’s NW 2.5% of local Citi Net Worth LLL 2: 15% of local Citi Net Worth Argentine residents can access the FX market to pay premiums, post guarantees and cancel transactions related to derivatives entered into with foreign counterparties governed by foreign law N/A 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 — Argentina Argentina

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