Emerging Markets Rates and Currencies Handbook

JSC “Citibank”, bank code 300584, NBU banking license #193 from 12/10/2011, in State register of banks from 11/05/1998 #274. License for professional activity in the capital markets for financial instruments trading, which includes brokerage and sub-brokerage activity, series AE #642056, valid from June 19, 2015. 16-g Dilova str. Kyiv 03150, Ukraine FX Sales Contact: +380-44-490 1025 Tax Summary – Ukraine Ukraine W/H Tax • • 15% Interest WHT • • Under certain tax treaties may be reduced • N/A • • Payments under derivative contacts are not subject to WHT, but non- resident’s gain derived from the sale of the derivatives subject to 15% WHT. • • Under DTAs may be reduced • • 15% Dividend WHT • • Under certain tax treaties may be reduced Deductibility of interests • • Generally deductible, with deduction limited according to thin capitalization and transfer pricing rules • • Thin capitalization rules: for entities if debts* to all non- resident exceeding equity by 3.5:1) Interest deduction is limited to 30% of amount (corporate income tax base + financial expenses + tax depreciation). This deductibility rule is not applicable to Financial Institutions, leasing companies and interest • • Generally deductible, but if offshore bank registered in low-tax jurisdiction (list approved by Cabinet of Ministers of Ukraine) deduction is limited according to transfer pricing rules • • • Thin capitalization rules do not apply to offshore banks • Fully deductible • There are no specific rules for corporate taxation of derivatives. The general rules of taxation therefore becomes applicable. In case of purchase derivatives from non- resident registered in low-tax jurisdiction (list approved by Cabinet of Minister of Ukraine) deduction limited according to transfer pricing rules • N/A Country Deductibility and Considerations Inter-Co Debt Offshore Bank Loans Offshore Local Borrowing Derivatives Equities