Emerging Markets Rates and Currencies Handbook

Tax Summary – Czech Republic Czech Republic participating loans are tax non-deductible. • EU ATAD interest stripping rules on top of thin cap rules (extra interest expenses may be disallowed). Net borrowing costs tax deductible only up to higher of either 30% tax adjusted EBITDA, or CZK 80 mm p.a. (safe harbour clause). * • Any tax non-deductible interest expense due to these rules may be carried forward for indefinite period and used as deduction in years where threshold not reached. • ATAD rules are not applicable for financial sector. tax non-deductible. • EU ATAD interest stripping rules on top of thin cap rules (extra interest expenses may be disallowed). Net borrowing costs tax deductible only up to higher of either 30% tax adjusted EBITDA, or CZK 80 mm p.a. (safe harbour clause). * • Any tax non-deductible interest expense due to these rules may be carried forward for indefinite period and used as deduction in years where threshold not reached. • ATAD rules are not applicable for financial sector Deductibility of (FX) Losses • Both realised and unrealized FX losses are tax-deductible (case-by-case review is recommended) Other Taxes/Duties • Neither stamp duties nor transfer taxes apply * Borrowing costs include various interest-like expenses, e.g. deemed interest expenses included in hedging instruments and in financial leasing costs, interest capitalised in value of assets and subsequently included in tax depreciation, and FX costs related to interest. 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 Deductibility and Considerations Inter-Co Debt Offshore Bank Loans Offshore Local Borrowing Derivatives Equities