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APPENDIX

TaxTreaties

European Union countries

Austria, Belgium, Bulgaria, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, The Netherlands, Poland, Portugal, Romania, Slovenia, Spain, Sweden, United Kingdom.

Other countries

Australia, Belarus, Bosnia and Herzegovina, Brazil, Canada, China, Croatia, Iceland, India, Indonesia, Israel, Japan, Kazachstan, Macedonia, Mexico, Moldova, Mongolia, Nigeria, Norway, Republic of South Africa, Russia, Serbia, Montenegro, Singapore, Sri Lanka, South Korea, Syria, Switzerland, Tunisia, Turkey, Turkmenistan, Ukraine, United States, Uzbekistan and Vietnam (Egypt – still to be signed or ratified or published).

Please note that as a general principle, a double taxation avoidance treaty is effective from the calendar year that follows the year in which the treaty becomes valid. Refer to the treaty concerned for further details.

Where two or more rates are quoted for dividends, in most cases the lower rate applies only to dividends received by certain corporations. Dividends sourced in Slovakia (from profits earned in 2004 and onwards) are in general not subject to any withholding tax in Slovakia. Where two or more rates are quoted for interest, often the lower rate applies only to interest received by banks. Where two or more rates are quoted for royalties, often the lower rate or nil rate applies for copyrights. Refer to the treaty concerned for further details.

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©2010 KPMG Slovensko spol. s r.o. , a Slovak limited liability company and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved.

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