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Common Market Practices

RAS COUNTRY OF ISSUE	RATE DESCRIPTION	ADDITIONAL COMMENTS
Belgium	Exempt - 0%	Documentation Required (IRS Form 6166 for all eligible U.S. entities).
	Favorable - 15%
	Unfavorable - 30%	All others
Canada	Exempt - 0%	Documentation Required: for exemption, tax-exempt organizations require a valid Canadian Exemption Number; a GlobeTax POA is required for the favorable rate. For Transparent entities, only long form processing is available.
	Favorable - 15%
	Unfavorable - 25%	All others
Czech Republic	Favorable - 15%, 10%, 8%, 5%	Documentation Required (IRS Form 6166 for eligible entities).
Czech Republic	Unfavorable - 35%	All others
Denmark*	Exempt - 0%	Documentation Required (IRS Form 6166 for all eligible U.S. entities).
	Favorable - 15%
	Unfavorable - 28%	All others
Finland	Exempt - 0%	Documentation Required (IRS Form 6166 for U.S. Pensions).
	Favorable - 15%	For all other eligible entities, IRS Form 6166 must exist on file (in-house rule).
	Unfavorable - 30%	All others
France	Favorable - 15%	Common Market Practice followed only for U.S. Individuals, per the beneficial owner data included in the daily beneficial owner file. Under CMP rules, U.S. Individuals are eligible to receive a favorable election. Documentation required (IRS Form 6166 for all other eligible U.S. entities, plus Form 8802 specific to U.S. RICs.
France	Unfavorable - 30%	All others. As of October 2017, U.S. Traditional IRAs are ineligible pending further filing requirements from the DR Depositaries.
Germany	Exempt - 0%	As of January 2017, U.S. Pensions and Charities are eligible for long form processes only.
	Favorable - 15%	Documentation required (IRS Form 6166 and any other relevant German forms for all eligible U.S. entities). As of January 2018, US RICs are eligible for long form processes only.
	Unfavorable - 26.375%	All others
Hungary	Exempt - 0%	Common Market Practice followed per the beneficial owner data included in the daily beneficial owner file. Under CMP rules, U.S. and other treaty residents categorized as "institutional" (non-individual) entities are eligible for the exempt rate.
Hungary	Unfavorable - 15%	All others
Indonesia	Favorable - 10%, 12%, 15%	Documentation Required (IRS Form 6166 for eligible entities).
Indonesia	Unfavorable - 20%	All others

RAS COUNTRY OF ISSUE	RATE DESCRIPTION	ADDITIONAL COMMENTS
Ireland	Exempt - 0%	Common Market Practice followed per beneficial owner information included in the daily record date files. Under CMP rules, U.S. residents are eligible for exemption; residents of other eligible markets may receive exemption via submission of Form V2/V3. For Partnership and Hybrid entities, only post payable processes are available.
Ireland	Unfavorable - 20%	All others
Israel Bonds (Acupay)	Exempt - 0%	Common Market Practice followed for non-Israeli treaty (including U.S. eligible resident Individuals (physical persons). Common Market Practice followed for non-Israeli treaty eligible tax resident (including U.S.) Legal Entities (non-Transparent entities). Common Market Practice followed for Israeli Financial Institutions (Banks). Israeli Residents with Israeli Certificate of 0% Withholding Document.
	Favorable - 24%	Common Market Practice followed for Israeli Corporations (other than Financial Institutions) with Israeli Certificate of 0% Withholding Document.
	Unfavorable - 25%	Common Market Practice followed for Israeli Individuals (physical person who was not an employee of the company).
	Unfavorable - 25%	All others
Italy (Equity)	Exempt - 0%	Documentation required (IRS Form 6166 for eligible entities).
	Favorable - 1.2%, 5%, 10%, 11%, 15%, 20%, 25%
	Unfavorable - 26%	All others
Italy (Bonds)	Exempt - 0%	Common Market Practice followed per the beneficial owner information included in the daily beneficial owner file. Under CMP rules, U.S. residents are eligible to receive exempt treatment.
Italy (Bonds)	Unfavorable - 26%	N/A
Japan (Equity)	Exempt - 0%	Documentation required (IRS Form 6166 for U.S. Pension & IRA entities).
	Favorable - 5%, 10%, 12.5%, 15%, 20.315%	Common Market Practice followed per the beneficial owner data included in the daily beneficial owner file. Under CMP rules, U.S. and other residents are eligible to receive favorable tax treatment. For Transparent entities, only long form processing is available.
	Statutory - 15.315%	All others
Japan (Bonds)	Exempt - 0%	Common Market Practice followed per the beneficial owner information included in the daily beneficial owner file. Under CMP rules, U.S. residents eligible to receive exempt treatment.
Japan (Bonds)	Statutory - 15.315%	N/A

RAS COUNTRY OF ISSUE	RATE DESCRIPTION	ADDITIONAL COMMENTS
Korea	Exempt - 0%	Common Market Practice followed per the beneficial owner data included in the daily beneficial owner file. Under CMP rules, U.S. and other treaty residents are eligible to receive a favorable election. For U.S. Overseas Investment Vehicles and Overseas Public Collective Investment Vehicles, only long form processing is available.
	Favorable - 5%, 7%, 10%, 11%, 12.5%, 15%, 15.4%, 16.5%, 20%	Documentation required (IRS Form 6166 for Pensions and Non-Profit Organizations).
	Unfavorable - 22%	All others
Netherlands	Exempt - 0%	Documentation required (IRS Form 6166 for Pensions and Non-Profit Organizations).
Netherlands	Unfavorable 15%	All others
New Zealand	Exempt - 0%	Documentation required (NZ Exemption Letter for U.S. Non-Profit Organizations).
	Favorable - 15%	Common Market Practice followed per the beneficial owner data included in the daily beneficial owner file. Under CMP rules, U.S. and other treaty residents are eligible to receive favorable tax treatment.
	Unfavorable - 30%	All others
Norway	Favorable - 15%	Documentation required (IRS form 6166 must exist on file for all treaty eligible entities (in-house rule).
Norway	Unfavorable - 25%	All others
Philippines	Favorable - 25%	Common Market Practice followed only for Individual entities per the beneficial owner information included in the daily beneficial owner file. Under CMP rules, Individuals are eligible to receive favorable tax treatment.
Philippines	Unfavorable - 30%	All others
Portugal **	Statutory - 25%	Common Market Practice followed for all non-Portuguese or Tax Haven (Individual) residents per the beneficial owner data included in the daily beneficial owner file.
	Statutory - 28%	Common Market Practice followed for all non-Portuguese and Tax Haven residents per the beneficial owner data included in the daily beneficial owner file. This is for all non-Individual (such as Pensions, Charities, Corps) eligible entities.
	Unfavorable - 35%	All others
Puerto Rico	Exempt - 0%	Documentation required (IRS Form 6166 for all eligible U.S. entities).
Puerto Rico	Unfavorable 10%	All others
Russia ***	Favorable - 0%, 5%, 10%, 12%	Documentation required (IRS Form 6166 with mention of DTT with Russia for all eligible U.S. entities).
Russia ***	Unfavorable - 15%	All others

RAS COUNTRY OF ISSUE	RATE DESCRIPTION	ADDITIONAL COMMENTS
South Africa	Exempt - 0%	Documentation required (IRS Form 6166 for eligible U.S. entities).
	Favorable - 5%, 10%, 15%	Documentation required (IRS Form 6166 for eligible U.S. entities).
	Unfavorable - 19%	All others
Spain (Equity)	Exempt - 0%	Documentation required (IRS form 6166 with mention of DTT with Spain for all eligible U.S. entities).
	Favorable - 1%, 5%, 10%, 12%, 15%, 18%	Documentation required (IRS form 6166 with mention of DTT with Spain for all eligible U.S. entities).
	Unfavorable - 19%	All others
Sweden	Exempt - 0%	Documentation required (IRS Form 6166 for U.S. Pensions).
	Favorable - 15%	For all other eligible entities, IRS Form 6166 must exist on file (in-house rule).
	Unfavorable - 30%	All others
Switzerland	Favorable - 15%	Common Market Practice followed for U.S. residents per the beneficial owner data included in the daily beneficial owner file. For U.S. Transparent Entities, additional beneficial owner requirements apply, including disclosure of the underlying investor(s). For U.S. Corporations and "Other" Entities holding above the DR equivalent of CHF 25,000, documentation (IRS Form 6166) is required. U.S. RICs holding above the DR equivalent of CHF 100,000 are not processed via relief at source (additional beneficiary documentation is required).
Switzerland	Unfavorable - 35%	All others
* Note: Effective 2015, Denmark's Novo Nordisk relief at source process was suspended.
** Note: Portugal RAS - Only the Statutory Rate can be claimed via DTCC's CA Web relief at source, if applicable. Otherwise, any further benefit may be gained via post payable recovery processes.
*** Note: Russia RAS - Additional costs to fulfill post payable audit requests may apply, client to instruct GlobeTax if there is a deviation from the standard processing.

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