Emerging Markets Rates and Currencies Handbook

Tax Summary – Philippines Philippines of FX losses purposes Other Taxes/Duties • DST of PHP 1.50 for every PHP 200, or fractional part thereof of the loan amount • N/A • On original issuance of stocks, DST of PHP 2.00 on each PHP 200, or fractional part thereof, of the par value of the stock • Exempt - Equities traded in Philippine Stock Exchange (PSE) Comments • N/A • Interest derived by a foreign government or its agencies is typically exempt from Philippine tax • It is prohibited to use onshore swap market to create ‘synthetic’ PHP borrowing, i.e. borrow USD offshore and swap to PHP onshore • N/A • N/A • A lower WHT on treaty countries generally applies if the beneficial owner of the dividends is a company with a substantial ownership (10- 25%; depending on country) in the dividend paying company 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 Bank Loans Offshore Local Borrowing Derivatives Equities Offshore