Emerging Markets Rates and Currencies Handbook

The following documents must be submitted to the bank • Board of Management Minutes on profit repatriation (BOM). • Audited Financial Report of the repatriation fiscal year. • Dividend Tax Declaration Form. Note: Payment only can be made after 7 working days since the receipt date of tax authority (including receipt date) or Tax confirmation for Tax fulfilment if we receive Tax Notification for client's tax obligation incomplete. Citibank N.A. Ho Chi Minh City Branch Sunwah Tower, 115 Nguyen Hue Boulevard District 1, Ho Chi Minh City, Vietnam Citibank N.A. Hanoi Branch Horison Tower, 40 Cat Linh Street, Dong Da District, Hanoi, Vietnam Corporate Sales & Solutions Contact: +84 28 3521 1245 / +84 28 3521 1280 Email : citivnfx@citi.com Tax Summary – Vietnam Vietnam Country Tax Deductibility and Considerations Inter-Co Debt Offshore Bank Loans Offshore Local Borrowing Derivatives Equities W/H Tax • 5% WHT • Under certain tax treaties typically 10%, with further reduction possible on country by country basis • No WHT • 2% WHT on IRS • 2% WHT on CitiConnect for SWIFT (CCS) • Bonds • 5%WHT on coupon • 0.1%WHT on income • Equities: • 0%WHT on dividend • 1%WHT on income Deductibility of interests • Cap on interest deduction to 30% of company’s EBITDA • Fully Deductible • N/A • N/A Deductibility of FX losses • Fully deductible • N/A Other Taxes/Duties • N/A • N/A • N/A • N/A • N/A Comments • Offshore loans must be in foreign currencies • A foreign loan can be made in any freely convertible foreign currency • Domestic loans are mostly required to be made in VND • Local Vietnamese banks may also make loans in a currency other than VND in very limited circumstances • N/A • TheWHT rates from the DTAs with Vietnam are higher, therefore those under the domestic law are applied instead 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