Emerging Markets Rates and Currencies Handbook

Tax Summary – El Salvador El Salvador of (FX) Losses Other Taxes/Duties • 13% VAT on the payment • VAT exempt if bank is qualified by Salvadoran Central Bank. • 13% if entity is not qualified. • VAT exempt if entity is Supervised by Financial Superintendence. • 13% VAT on the payment • N/A Comments • Operation should be documented in agreement. • Interests and conditions should be of FMV and documented in transfer pricing study. • Operation should be documented in agreement. • 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 Local Borrowing Bank Loans Offshore