Emerging Markets Rates and Currencies Handbook

Documentation Requirements No local law requirements on specific form or type of trade documentation to be used. Trade Flows No local law requirements on specific form or type of trade documentation to be used. Capital Flow and FDI No local law requirements on specific form or type of trade documentation to be used. Additional Comments Hedges are allowed for balance sheet flows and cash flow exposures. Citibank Hong Kong 50/F Champion Tower 3 Garden Road Central, Hong Kong FX Sales Contact: +852 2868 8231 Tax Summary – Hong Kong Hong Kong W/H Tax • No WHT • Treaties provide for a maximumWHT rate on interest should it be imposed in the future • N/A • No WHT • Treaties provide for a maximum WHT rate on interest should it be imposed in the future Deductibility of interests • There are no thin cap rules in Hong Kong but there are specific interest • deductibility rules that apply • Subject to stringent rules designed to guard against loan arrangements with an • intention to avoid Hong Kong profits taxes • N/A • N/A Deductibility of FX losses • Deductibility of FX losses depends on the underlying transactions • Realized foreign exchange losses arising from capital transactions: Non-deductible • Realized foreign exchange losses arising from revenue transactions: Deductible • Unrealized losses arising from financial instruments that are Hong Kong sourced, revenue in nature, recognized in the P&L and are specifically impaired, are deductible if an irrevocable election is made to file the profits tax return in accordance with financial statements prepared under IFRS 9. Other Taxes/Duties • N/A • N/A • N/A • N/A • N/A Comments • 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 Tax Deductibility and Considerations Inter-Co Debt Offshore Derivatives Equities Bank Loans Offshore Local Borrowing