Emerging Markets Rates and Currencies Handbook

Tax Summary – Pakistan Pakistan for exemption under clause • (132C) of Part-I of this Schedule, rate of WHT is 7.5%. • Reduced rate may apply under relevant DTA Deductibility of interests • Deductible expense, subject to conditions specified under sections 106 and 106A of the Ordinance • Transaction should be on an arm’s length basis • Loan agreement should be registered with the State Bank of Pakistan • Deductible expense • Transaction should be on an arm’s length basis • N/A • N/A Deductibility of (FX) Losses • Deductible expense on realized basis • N/A • Deductible expense on realized basis • N/A Other Taxes/Duties • N/A • N/A • N/A • N/A • 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 Country Deductibility and Considerations Inter-Co Debt Offshore Bank Loans Offshore Local Borrowing Derivatives Equities