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Sg Issuer 23 | LSE:58KL | London | Medium Term Loan |
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RNS Number:7152K Caja De Ahorros Y Monte de Piedad 27 December 2007 Notices by CAJA MADRID (Caja de Ahorros y Monte de Piedad de Madrid) With Respect to its Extendible Short Term Notes Initially Due on October 19, 2007 and with a Final Maturity Date of October 19, 2011 Bearing the Original CUSIP: 12802LAA6 Record Date: January 7, 2008 Recommended Deadline: January 15, 2008 Interest Payment Date: January 22, 2008 Issuer notice regarding Spanish Beginning on January 8, 2008 (8:00 a.m. EST) and continuing until January 15, 2008 withholding tax requirements. (8:00 p.m. EST), in order to secure relief-at-source from Spanish withholding tax, DTC participants must (i) enter into the Acupay System information about beneficial owners who are exempt from Spanish Non-Resident Income Tax ("NRIT"), (ii) prepare and send Spanish tax certificates with respect to such clients and (iii) make corresponding DTC EDS elections. These steps should be undertaken in accordance with the procedures laid out in this DTC Important Notice. Failure to do so could result in withholding of 18% of the income that would be otherwise received. Issuer Notice of Extension Election Holders of the notes are invited to transmit elections to extend the maturity of Period the notes to February 12, 2009. The election period will begin on January 8, 2008 at 9:00 a.m. Elections to extend the maturity date of the notes must be received by the custodian bank or broker holding the notes in sufficient time so that information relating to such extensions can be entered by such custodian bank or broker in both the Acupay System and also in DTC's APUT system by the Recommended Deadline, or under special circumstances until 5:00 p.m. New York City time on January 18, 2008). Please check with your custodian bank or broker to learn of any particular deadlines they may impose to receive such elections. A holder who does not elect to extend the maturity of his notes will be subject to a mandatory exchange of his notes into non-extendible notes due November 12, 2008. Such non-extendible notes bearing CUSIP 12802LAF5 would be delivered on January 22, 2008. Information regarding the timing of the current election period and each subsequent period is set forth below: Interest Payment Date Maturity, if Extended Maturity, if NOT Extended January 22, 2008 February 12, 2009 November 12, 2008 April 19, 2008 May 13, 2009 February 12, 2009 July 19, 2008 August 13, 2009 May 13, 2009 October 19, 2008 November 13, 2009 August 13, 2009 January 19, 2009 February 12, 2010 November 13, 2009 April 19, 2009 May 13, 2010 February 12, 2010 July 19, 2009 August 13, 2010 May 13, 2010 October 19, 2009 November 12, 2010 August 13, 2010 January 19, 2010 February 11, 2011 November 12, 2010 April 19, 2010 May 13, 2011 February 11, 2011 July 19, 2010 August 12, 2011 May 13, 2011 October 19, 2010 October 19, 2011 August 12, 2011 January 19, 2011 N/A October 19, 2011 April 19, 2011 N/A October 19, 2011 July 19, 2011 N/A October 19, 2011 October 19, 2011 N/A N/A Detailed Operational Procedures and Guidelines regarding CAJA MADRID (Caja de Ahorros y Monte de Piedad de Madrid) With Respect to its Extendible Short Term Notes Initially Due on October 19, 2007 and with a Final Maturity Date of October 19, 2011 Background information about Pursuant to Law 13/1985 (as amended by Law 19/2003 and Law 23/2005) and Royal Spanish tax law requirements Decree 2281/1998 (as amended by Royal Decree 1778/2004), income derived from the above securities by a Non-Spanish resident holder who does not act with respect to such securities through a permanent establishment in Spain or a Spanish resident corporation will not be subject either to the 18% Non-Resident Income Tax (NRIT) in Spain or to a 18% withholding rate on account of the Spanish Corporate Income Tax unless the non-resident holder (i) derives the income through a "tax haven" territory (as defined in Royal Decree 1080/1991 of 5 July 1991) or (ii) fails to comply with the relevant tax residency certification procedures as described below. Should a U.S.-based DTC participant hold securities on behalf of an institution located in a tax haven country, who is then holding the securities on behalf of an otherwise entitled beneficial owner (such as a U.S. resident), the beneficial owner would not be entitled to receive exemption from withholding tax on those securities. Please refer to Annex A for a list of tax haven countries and territories. Participants requesting exemption from Spanish NRIT via DTC's Elective Dividend Service (EDS) are required to provide beneficial owner tax information in support of their DTC EDS elections. The Issuer, the Guarantor and the Issuing and Paying Agent have arranged certain procedures with DTC and Acupay System to facilitate the collection from participants of such information concerning the identity and residence of the beneficial owners of the securities. Failure to (i) certify via EDS, (ii) provide beneficial owner information via Acupay, or (iii) to follow the required procedures, will result in 18% withholding from the interest payment. Summary of steps you will need to 1. Register to use the Acupay System. take 2. Transmit to your clients the Issuer's Notice of Extension Election Period. Solicit your clients' response to the notice. Details on each step follow below. 3. Upload beneficial owner information into Acupay System. 4. Print, sign and send Spanish tax certificates. 5. Make "DTC APUT" instruction(s) recapping your clients' extension elections. 6. Make summary tax election via DTC's EDS. 1.Register to use the Acupay System DTC participants must visit the Acupay System website at www.acupaysystem.com and register (i) their institution, (ii) one or more authorized employees who will be responsible for making tax certifications on the behalf of the DTC participant and (iii) financial intermediaries (i.e. "downstream correspondents") for which the DTC participants provide clearing arrangements on an "omnibus" basis. 1.A. Already registered? Then move If the participant, its downstream correspondents, or members of their respective on to Step 2! teams, were previously registered to use the Acupay System (for this or any other securities issue), there is no need to register again - their existing login details should still work 1.B. If you're not registered...but DTC participants that are located in OECD (Organization for Economic Co-operation you're in an OECD Country...you're and Development) countries are permitted to register in the Acupay System and to invited! participate in the "tax relief-at-source" procedures including the submission of beneficial owner extension information. Please refer to Annex B for a list of OECD Countries. 1.C. Neither registered, nor in an DTC participants that are located in a country with which Spain has entered into a OECD Country?...maybe you're in a treaty for the avoidance of double taxation (Tax Treaty Countries) are permitted to "Tax Treaty" country...if so, register in the Acupay System and to participate in the tax relief-at-source you're invited! procedures including the submission of beneficial owner extension information. Please refer to Annex C for a list of Tax Treaty Countries. 1.D. Not registered and not located in an OECD or Tax Treaty Country? DTC participants or their downstream correspondents which are not located in OECD (Organisation for Economic Co-operation and Development) Countries or in a country with which Spain has entered into a Treaty for the Avoidance of Double Taxation (Tax Treaty Countries) will be allowed to register in the Acupay System for the purpose of submitting beneficial owner extension information but will not be eligible to participate in the "Relief-at-Source Procedures". Such entities may, however, follow the "Quick Refund Procedures" discussed below. Please refer to Annex B and C respectively for a list of OECD Countries and Tax Treaty Countries. DTC participants and downstream correspondents located in tax haven countries are allowed to register in the Acupay System for the purpose of submitting beneficial owner extension information but are not eligible to use the Acupay System to submit beneficial owner tax information, nor to use DTC's EDS for Spain. 1.E. If you "clear" for other IMPORTANT: Participants that clear for downstream correspondents on an omnibus firms, please register them to use basis are subject to revised operational requirements regarding entering beneficial Acupay! owner information into the Acupay System. To comply with Spanish tax regulations and "Know Your Customer" policies mandated by the USA PATRIOT Act, Participants may not enter beneficial owner information into the Acupay System on behalf of their omnibus downstream correspondents. Omnibus downstream correspondents are required to enter their beneficial owner client information directly and Participants must confirm their downstream correspondents' aggregate omnibus positions. Please read the procedures in 3.C below carefully. 2. Transmit to your clients the Caja Madrid requests that you transmit to your clients the Notice of Extension Issuer's Notice of Extension Election Period. Caja Madrid will reimburse participants for their reasonable costs Election Period. Solicit your in transmitting the notice. The notice is dated December 27, 2007. clients' response to the notice. Caja Madrid also requests that you solicit responses from your clients who are the beneficial owners. Once your clients provide you with their response, you should promptly enter their response in both the Acupay System and DTC's APUT system. This should be done as described in Steps 3 and 5. Don't wait to "batch-together" multiple client responses - Keep your entries current! The Issuer's notice indicates that holders of the notes are invited to elect to extend the maturity of their notes. In the absence of any response, your clients' notes will be mandatorily exchanged with notes that mature on November 12, 2008. However, if your clients elect to extend the maturity date of the notes, the maturity of their notes will be extended to February 12, 2009. PLEASE NOTE: Extension election procedures like these will take place quarterly until October 2010. 3. Enter beneficial owner As soon as you get a response from your clients (i.e. the beneficial owners) on Information in the Acupay System whether or not they wish to extend the maturity of their notes, you should before January 22, 2008 immediately enter such information into the Acupay System. (9:45:00 AM) For reasons that will become clearer as you read this instruction, it is essential that this information be entered FIRST before any entries are made in DTC's APUT or EDS systems. It is important that this step be completed by the Acupay System Recommended Deadline of January 15, 2008 8:00 p.m. EST. However, in the case of late settling trades additional entries can be made until January 18, 2008 at 8:00 p.m. In the case of trades settling on the Interest Payment Date (January 22, 2008) the Acupay System will be available on that day until 9:45 a.m. EST to permit late entry of information (or changes to previously entered information). 3.A. Five types of information This is the information you will need to enter about each beneficial owner: Some needed about each BO. information is required, while other information can be provided at your option (to help you "tie-back" entries to your firm's records. Mandatory Information 1. Name of the investor (not the name of the external fund manager or the BO's custodian bank - instead, you should supply the name of the entity which beneficially owns the security). 2. Country of residence of the beneficial owner. 3. Amount of notes to be held on Interest Payment Date by the beneficial owner (you can enter the amount of securities held on the day you enter the information, but remember, please update that amount if the client's position changes between then and the Interest Payment Date. The notes can be identified in the Acupay System using either their original CUSIP or the Contra CUSIP associated with extension elections. 4. Extension Amount. - The amount of the BO's notes for which you have received a request from the investor to extend the maturity until February 12, 2009. 5. For Spanish Corporate Investors Only - the beneficial owner's Street Address and Tax Identification Number. Optional Information 1. Tax ID (This is mandatory for investors who are Spanish corporations). 2. Account Number of the beneficial owner at your custodian bank or brokerage. 3. Client address and telephone number. (Please remember that addresses are mandatory for Spanish corporate investors). 3.B. Three Acupay methods are These are the three methods. Complete details, and "help" regarding each method are available for entering beneficial available on the Acupay website. owner details. 1. One-by-One Method - participants with a small number of beneficial owners may use this method to separately enter individual beneficial owner information. 2. Bulk "Cut-and-paste" Method - participants with a larger number of clients can use this method to (i) download client data from their internal systems, (ii) paste this data into a formatted Excel spreadsheet and (iii) paste the spreadsheet into a secure Acupay "upload portal". 3. Renew Previous Submissions Method-Through a single "push of a button" a participant can confirm that previous beneficial owners (and their related information), which were submitted for a previous payment period, are still valid for the current period. 3.C. Confirm total holdings of DTC participants that provide clearing arrangements for downstream correspondents, downstream omnibus clearing irrespective of whether such downstream correspondents are Qualified Intermediaries clients. (as described by the US IRS in Revenue Procedure 2000-12 found in Cumulative Bulletin 2000-1 of Internal Revenue Bulletin 2000-4) should: i. Register their downstream correspondents in the Acupay System by entering the details of such downstream correspondents directly into the "Add a New Registered Downstream Correspondent" section of their Acupay System account, or by allowing such downstream correspondents to register themselves by providing them with the Acupay Registration Code found within the "View Downstream Correspondent Registrations" section of the Acupay System. * Once registered the downstream correspondents will be able to process Acupay tax relief-at-source client certifications for their own clients. Since downstream correspondents are required to "know their clients", it is logical that they are the entities, which should enter client information regarding their clients into the Acupay System - not the upstream clearer (which is a DTC participant). ii. Confirm the downstream correspondent's omnibus position. The DTC participant should confirm the aggregate position in the securities held on the behalf of each of its downstream correspondents. This confirmation is made ONLY with regard to the aggregate omnibus amount held by the downstream correspondents, NOT with regard to the identity or details of the end investor clients of the downstream correspondents. These aggregate position confirmations should be kept updated through 9:45 a.m. on the Interest Payment Date (just like all other information entered in the Acupay System). iii. Make the necessary EDS elections, to match the total amount of Acupay certifications made by the downstream correspondent(s). 3.D. Update Acupay data as The Recommended Deadline is January 15, 2008. However, it is the responsibility of necessary until the Interest DTC participants and their correspondents to update beneficial owner information Payment Date. entered in the Acupay System as necessary to keep it in synch with clients' actual positions. Updating must continue until 9:45 a.m. on January 22, 2008 (the Interest Payment Date). 4. Print out, review, sign and send Once beneficial owner information has been entered into the Acupay System, the tax certificates. system will produce, as applicable, Spanish tax certificates (I, II or III) for the interest income to be received by the beneficial owner. These certificates must be reviewed, printed, signed (if accurate), scanned and emailed to certify@acupay.com or faxed to Acupay at +1-646-383-9489 or +44-207-067-8453. In the event that a beneficial owner has declined to extend the maturity of its notes the Acupay System will produce a second set of tax certificates (but only if non-extension will produce a taxable gain). This second set of certificates will need to be printed, reviewed, signed (if accurate) and sent in addition to the interest income tax certificates. 4.A. Only use official Acupay tax Participants MUST use the tax certificates that are generated by the Acupay System certificates (showing the official Acupay bar code) as no other form of tax certificate will be accepted. Acupay submissions (including beneficial owner information) will not be processed until Acupay has received signed tax certificates, as described above. 4.B. Keep certificates accurate If any changes occur to the facts set out in tax certificates (between the date of until January 22, 2008. submission and the Interest Payment Date), participants are required to prepare and submit replacement certificates reflecting such changes. Care should be employed to assure that information in the tax certificates is kept "in-synch" with related summary information entered into the DTC APUT system and also in DTC EDS. All three "platforms" should be kept in-synch. 4.C. By February 15, 2008, original After the Interest Payment Date participants should send, via post or courier to paper versions should be received Acupay the original, signed copies of any tax certificates I, II and III that were in London previously faxed or emailed as described above. These original paper signed tax certificates MUST be received by Acupay by no later than 5:00 p.m. London time on February 15, 2008 at the following address: Acupay System LLC Certifications Attn: Maria Dolores Lopez Perez 28 Throgmorton St - First Floor London EC2N 2AN United Kingdom Telephone: +44-207-382-0340 PLEASE NOTE: A participant that obtains favorable tax treatment through these tax relief-at-source procedures and fails to submit the original physical certificates as described above, will be prohibited by the Issuer from using the procedure to obtain favorable tax treatment for future payments. In such event, the participant will receive any future interest payment on its entire position net of 18% NRIT withholding tax and relief will need to be obtained directly from the Spanish tax authorities by following the standard refund procedure established by Spanish tax law. 5. Enter "DTC APUT" instruction(s) The DTC APUT system will be available for participants to enter "summary elections" recapping all Extension elections for all of the beneficial owners for whom extension elections have been received and entered into the Acupay System by the participant and its downstream correspondents. APUT entries can be made commencing on the morning of January 8, 2008. 5.A. Try to complete APUT entries Both APUT and EDS will operate during parallel time periods. For reasons that will before making EDS entries. be explained at step "6" it is important that all APUT entries be completed before EDS entries. This relates to the impact of shifts from target CUSIPs to Contra CUSIPs occurring during the APUT process. It is important that all EDS entries be made using Contra's (if the related notes will "reside" in the Contra by Interest Payment Date). Therefore, securities being "elected" for extension should be moved into their Contra's first before EDS entries are attempted (assuming that notes are being both elected for extension and requested for tax relief). Both DTC systems will open on January 8, 2008. And the Recommended Deadline for both systems is January 15, 2008. Of course, the APUT automated system routinely "closes" at 12:00 p.m. while the EDS automated system operates until 8:00 p.m. 5.B. Late settlement APUT entries The APUT system will be open for late entries and adjustments after the Recommended and adjustments. Deadline, as follows: * Until 12:00 noon each New York business day until January 18, 2008 for automated entries. This is called the "APUT Automated Deadline". * After 12:00 noon and until 5:00 p.m. via manual requests to DTC staff until January 18, 2008. We wish to remind you that entries in APUT must generally be followed by entries in DTC's EDS. Therefore late entries in APUT will require close and careful coordination with EDS in order to assure proper processing of tax relief. 5.C. Keep APUT in-synch with ACUPAY APUT entries must be kept in alignment with corresponding beneficial owner data entered in the Acupay System (and related Spanish tax certificates). 6. Make summary tax elections via Beginning at 9 a.m. on January 8, 2008 and continuing until 8 p.m. New York time on DTC's EDS. January 15, 2008 (the Recommended Deadline), DTC participants must make an election via DTC EDS summarizing the aggregate positions that they reported via Acupay (and certified on Spanish tax certificates) as being exempt from Spanish withholding tax. The DTC EDS operates daily from 8:00 a.m. until 8:00 p.m. 6.A. Use the Contra-CUSIP obtained Historically, close to 100% of all holders of extendible notes elect to extend from APUT operation for related EDS their notes. And, "elections to extend" these notes necessitate the undertaking of elections. APUT instructions by DTC participants - with a resultant movement of the securities from the original "target CUSIP" into a temporary Contra CUSIP. The "elected" notes will remain in the Contra CUSIP until late in the afternoon on the Interest Payment Date, after interest payments have been allocated to DTC participants. It is only after payment has been effected that "extended" notes are returned to the original CUSIP. Therefore, it is clear that interest will be paid on Interest Payment Date to the holders of the following CUSIPs: * Contra CUSIPs with respect to all holders who had elected to extend their notes. * Original CUSIPs with respect to only those holders who declined to extend their notes. In order for your clients who are exempt from the operation of Spanish withholding tax to be paid WITHOUT withholding, it is absolutely necessary that a DTC EDS election be made with respect to the CUSIP that will actually be paid on the Interest Payment Date. Therefore, it is important that whomever on the staff of the DTC participant who performs the DTC EDS entry be aware of the previous work "done" by the team responsible for APUT instructions. To summarize: For notes that have been elected to be extended via APUT, EDS instructions must be entered in the Contra CUSIP. For notes that have not been elected to be extended via APUT, EDS instructions must be entered in the Original CUSIP. Finally, both EDS and APUT need to be kept in alignment with beneficial owner information and certifications entered via Acupay. PLEASE NOTE: In order for the DTC participant to receive interest on the Interest Payment Date free of NRIT withholding (for further credit to their clients who are exempt from Spanish NRIT) the aggregate amounts certified through the Acupay System and those elected through DTC EDS must be in synch. It is the responsibility of each participant to ensure that the principal amount of notes, which they certify via Acupay, is equal to the principal amount of notes for which they have made DTC EDS elections at the exempt rate. Data introduced in both DTC EDS and Acupay may be modified by the participant (in both systems) until 8 p.m. New York time on January 18, 2008. 6.B. Finish EDS entries last. EDS entries ought to be made last....after Acupay and APUT. Of course, entries made through all three systems need to be kept updated and accurate until the morning of the Interest Payment Date. 6.C. Last minute manual EDS DTC participants whose Acupay certifications and EDS elections are out of alignment adjustments on Payment Date. on the morning of the Interest Payment Date may request that DTC manually modify EDS elections to bring them into alignment by sending an EDS change request to DTC via email at SBollers@DTCC.com no later than 9:45 a.m. New York time on January 22, 2007, with a copy to MMejia@DTCC.com, Lbottigl@DTCC.COM; RNEVES@DTCC.COM AND EDS@acupay.com. Likewise, it is the responsibility of DTC participants and their correspondents to update beneficial owner information entered in the Acupay System as necessary to keep it in synch with clients' actual positions. Updating must continue until 9:45 a.m. New York time on January 22, 2007. 6.D. All systems must be in-synch. DTC participants must ensure that EDS elections entered into DTC and beneficial owner data entered into the Acupay System are synchronized and updated to reflect any changes to beneficial ownership or DTC positions occurring prior to 9:45 a.m. on January 22, 2008 (the Interest Payment Date). The failure to correct any inconsistency between (i) DTC EDS elections and tax certificates and (ii) if an exchange operation is calculated to produce taxable income, beneficial owner Extension Information and DTC Extension elections (including any misalignment between the total par amount of notes to be exchanged for Non-Extendible notes by any DTC participant account (arising from the absence of timely DTC Extension elections) and the total par amount of notes to be exchanged for Non-Extendible notes determined via the related beneficial owner Extension Information supplied by the DTC participant via the Acupay System), including the failure to fax or send PDF copies of new or amended tax certificates by 9:45 a.m. on the relevant Interest Payment Date (or if Acupay does not confirm receipt of a communication of such correction by 9:45 a.m. on the relevant Interest Payment Date) will result in the payments in respect of the entirety of such participant's position being made net of Spanish withholding taxes. Notwithstanding any such error or inconsistency, all DTC Extension elections (and revocations of such extension elections) will be accepted by Acupay and will not result in an exchange of notes for Non-Extendible notes if such elections are made on a timely basis and in an amount equal to or less than the relevant participant's aggregate DTC position in the notes at the date and time submitted. 7. Quick Refund procedure. Beneficial owners who received interest net of 18% NRIT withholding due to a misalignment of their EDS elections, APUT instructions and Acupay tax certifications may qualify for a refund through the Quick Refund Procedure. To utilize this procedure, participants must have submitted valid EDS elections during the tax relief-at-source EDS "window". Relief may be obtained only up to the amount of securities for which an EDS election was properly received by DTC as of 9:45 a.m. on January 22, 2008. Refunds through the Quick Refund Procedure are not available for any position that was not previously elected for gross (exempt) treatment via EDS on or before 9:45 a.m. on the Interest Payment Date. Participants may use the Acupay System to request relief through the Quick Refund Procedures on behalf of their clients beginning January 23, 2008 and continuing until February 8, 2008 at 5:00 p.m. New York time. 8. Direct refund from Spain. If participants have not certified for any reason through the Relief at Source or Quick Refund Procedure and have received unfavorable tax treatment, eligible investors may request a tax refund from the Spanish tax authorities by following the Direct Refund procedure established by Spanish tax law. 9. DTC participants are responsible By submitting EDS elections and Acupay submissions and tax certifications DTC for their submissions. participants agree that they will indemnify Caja Madrid and its agents for any liability which they may incur as a result of reliance upon such information provided by such participant. The DTC participant also agrees to return any funds erroneously received (including any interest, penalties and additions to tax thereon) arising from its EDS elections and Acupay certifications. 10. Where to get additional Questions regarding the APUT process should be directed to David Cybroski of DTC's information. Reorganization Department at (212) 855- 5137. Questions regarding the EDS process should be directed to Sean Bollers or Larry Bottiglieri of DTC's International Services team at (212) 855-4706 or 4386 respectively. General questions regarding these operational procedures and the related Spanish tax laws, as well as the specific Acupay informational procedures identified here (or the use of the Acupay System) should be directed to Monica Medina Navarro at +1-212-422-1222 or Maria Dolores Lopez Perez at +44-207-382-0340 or by emailing info@acupay.com. 11. Postscript: Tax treatment of For the purpose of completeness we wish to point out that Spanish tax law provides gains from non-extension. for the operation of tax withholding procedures on the gains (if any) obtained by investors who do not extend their notes (and thereafter exchange their notes for non-extendible notes). Although such gains arising out of such an exchange are theoretically possible, in practice they are highly unlikely to occur. However, in the unlikely event that such gains were to arise, then the Acupay System would announce the existence of such gains and the related requirement for participants to participate in the operation of certain special withholding tax procedures. Such procedures embrace steps intended to assure either (i) the collection of required information certifying the exemption of investors from the operation of such tax or (ii) withholding the appropriate amount of such tax from investors (via their DTC participant). These steps are laid out in Annex A to the Offering Memorandum of Caja Madrid dated September 22, 2006 which can be downloaded from www.acupaysystem.com/cajamadrid/offeringmemo. Annex A Tax-Haven Countries & Territories Andorra, Principality of Jamaica Monaco, Principality of Anguila, The Island of Jersey, Channel Islands Montserrat Antigua and Barbuda, Islands of Jordan, Hashemite Kingdom of Nauru, Republic of Aruba Lebanon, Republic of Netherlands Antilles Bahamas, The Liberia, Republic of Northern Mariana Islands Bahrain, Kingdom of Liechtenstein, Principality of Oman, Sultanate of Barbados, The Island Luxembourg, Grand Duchy of (but only as Panama, Republic of regards to the income received by the Bermuda Islands, The companies referred to in paragraph 1 of Saint Lucia the Protocol annexed to the Avoidance Brunei, Sultanate of of Double Taxation Treaty, dated 3rd Saint Vincent and the Grenadines June 1986, entered into by Spain and Cayman Islands Luxembourg i.e., those holding San Marino, Republic of companies as defined by Luxembourg Law Cook Islands, The of July 31, 1929 and Luxembourg Grand Seychelles, Republic of Ducal Decree of December 17, 1938) Cyprus, Republic of Singapore, Republic of Macao Dominica, The Republic of Solomon Islands Mauritius Falkland Islands Trinidad and Tobago, Republic of Fiji Islands Turks and Caicos Islands Gibraltar Vanuatu, Republic of Grenada Virgin Islands, British Guernsey, Channel Islands Virgin Islands, of the United States Hong Kong Isle of Man Annex B OECD Countries Australia Hungary Norway Austria Iceland Poland Belgium Ireland Portugal Canada Italy Slovakia Czech Republic Japan Spain Denmark Korea, Republic of Sweden Finland Luxembourg Switzerland France Mexico Turkey Germany Netherlands United Kingdom Greece New Zealand United States Annex C Spanish Tax Treaty Countries Algeria Georgia* Netherlands Argentina Germany New Zealand Armenia* Greece Norway Australia Hungary Philippines Austria Iceland Poland Azerbaijan* India Portugal Belarus* Indonesia Romania Belgium Iran, Islamic Republic of Russia* Bolivia Ireland Slovakia Brazil Israel Slovenia Bulgaria Italy Sweden Canada Japan Switzerland Chile Kazakhstan* Tajikistan* China Korea, Republic of Thailand Croatia Kyrgyzstan* Tunisia Cuba Latvia* Turkey Czech Republic Lithuania* Turkmenistan* Denmark Luxembourg Ukraine* Ecuador Macedonia, The Former Yugoslav Republic United Arab Emirates of Egypt United Kingdom Malta, Republic of Estonia* United States Mexico Finland Uzbekistan* Moldova, Republic of* France Venezuela Morocco Vietnam * The countries of the former USSR are covered together under treaty (Russia covered under separate treaty). This information is provided by RNS The company news service from the London Stock Exchange END MSCEAXAXAFEXFFE
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