Emerging Markets Rates and Currencies Handbook

Tax Summary – Romania Romania W/H Tax • 16% Interest WHT • Under certain tax treaties can be reduced • WHT exemption if conditions are met: Interest paid to related parties in EU and for 2 years before payment: the payer / recipient own min 25% shares or 3rd party in EU owns min 25% in both payer and recipient • 50% WHT on interest paid to countries with no tax exchange of information agreement (TEIA) regardless if DTA or not. This applies only to "artificial transactions” • No WHT • Cross currency swap with exchange of notional is subject of WHT in Romania (16% or gross up) • Transactions with derivatives for risk management of public debt are WHT exempted • 8%WHT on dividends • Under certain tax treaties can be reduced • EU Parent- Subsidiary Directive: Dividends paid to companies resident in EU are WHT exempt if beneficiary has held, min 10% of shares for an uninterrupted period of 1 year Deductibility of interests • Net borrowing costs (debt-related costs, incl. FX expenses and capitalised interest, minus interest income) that exceed the deductible threshold of EUR 1 mm, are deductible, up to the limit of 30% of the calculation base • Calculation base = (gross accounting profit - non- taxable revenues + profits tax + net borrowing costs + deductible tax depreciation) • The non-deductible net borrowing costs can be carried forward indefinitely Deductibility of (FX) Losses • FX losses linked to loans or financing instruments are subject of limited deductibility 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