Emerging Markets Rates and Currencies Handbook

Tax Summary – Argentina Argentina of (FX) Losses derivative” – Yes • “Speculative derivatives” – Only against gains from other speculative derivatives 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” • 7% Tax on dividends at payment. • 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 Country Tax Deductibility and Considerations Inter-Co Debt Offshore Derivatives Equities Bank Loans Offshore Local Borrowing