A M E R I C A

B R A Z I L

Increase of social contribution on gross income for listed business sectors published

A bill approved on 31 August 2015 and in forcesince then, has increased the social contribution on gross income for listed business sectors: from 2% to 4.5% for certain listed business sectors (e.g. information technology and hotels); from 1% to 2.5% for certain listed business sectors (e.g. toy production and aircraft maintenance), etc.

Rules on 2016 withholding tax return published

A Normative Instruction published in the Official Gazette of 18 September 2015, established the rules for filing the 2016 withholding tax return that must be filed by 29 February of 2016, related to income tax withheld in tax year 2015. Among other rules, the beneficiaries of salaries exceeding BRL 28,123.90 must be included in the DIRF 2016 as well as payments of private health insurance plans made by the employer for the benefit of employees, the name and tax registration number of the employees, and their dependants.

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TA X & S O C I A L S E C U R I T YI N T E R N AT I O N A L N E W S

AMERICA Brazil Colombia Costa Rica Honduras Mexico Peru Uruguay VenezuelaASIA - PACIFIC Azerbaijan China Israel Kazakhstan Qatar Saudi Arabia UzbekistanEUROPE Belgium France Finland Ireland Italy Netherlands Norway Russia Sweden Switzerland United KingdomAFRICA Mozambique Nigeria South AfricaTAX TREATIES SIGNED

C O L O M B I A

Constitutional Court considers regularization tax to be in accordance with Constitution

In a recently published official communique of August, the Constitutional Court (CC) decided on the claim of unconstitutionality against the recent Law that contains the tax reform, which established the regularization tax as a surtax to the wealth tax. In CC’s opinion, the provisions regarding the taxpayer, taxable base, taxable event and tax rate of the regularization tax are in accordance with the Constitution. The claimants said the tax amnesty was contrary to the Constitution as it provided an unjustified benefit to non-compliant taxpayers.

Proposal for administrative regulation on foreign assets return

The DIAN recently published a proposal for an administrative regulation on the foreign assets return created by a Law of 2014. Form 160 has to be used for reporting electronically using the digital signature issued by DIAN the foreign assets by income taxpayers subject to income tax on their worldwide income and assets, and owning foreign assets at 1 January of the corresponding tax year. If failing, or late filing, a penalty will be applicable.

New wealth tax for foreign individuals approved

The National Tax Authority pronounced on the wealth tax applicable on foreign individuals who are subject to wealth tax (possession of wealth exceeding COP 1 billion as at 1 January 2015). Foreign individuals who have been residents of Colombia less than 5 years may exclude from the taxable base their net wealth owned abroad. If tax resident in Colombia at 1 January 2015, but who not for more than 5 years, with a worldwide wealth exceeded COP 1 billion as at that date, DIAN’s opinion is that the individual is an Colombian income taxpayer.

National Tax Authority rules on tax compliance by non-resident individuals

Following the National Tax Code (TC), non-resident individuals, nationals or foreigners, are subject to income tax in Colombia in respect of their Colombian-source income but are not required to file an income tax return when their Colombian-source If the Colombian-source income received by a non-resident individual, whether a national or foreigner, was not subject to WHT, the non-resident individual is required to file an income tax return, being subject to a 33% income tax rate for non-resident individuals.

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C O S T A R I C A

Residence certificate and conditions for application of treaties to New income tax brackets for taxable year 2015-16

On 25 September 2015, an Executive Decree was published in the Official Gazette and in force as from 1 October, established new income tax brackets for the taxable year 2015-16 (i.e. taxable year from 1 October 2015 to 30 September 2016), that in case of individual income tax regarding employment income stand rates from 10% to 15%.

H O N D U R A S

New Social Protection System Law enters into force

The Social Protection System Law that entered into force on 4 September 2015, creates a “multi-pillar” social protection system integrated by the Social Protection Floor system, a non-contributory system funded by the government; the Social Security system, a contributory system funded through contributions paid to the Honduran Social Security Institute by employees and the own government; the Health Insurance system, a contributory system funded through contributions paid to the Honduran Social Security Institute by employees and the own government; the Occupational Accident Insurance system, that regulates the employer’s obligation to provide an occupational accident insurance to the employee; and an Unemployment Insurance system, a contributory system funded through contributions paid by the employer to the employee’s capitalization subaccounts of 4% of the monthly salary.

M E X I C O

Tax measures of Budget for 2016 approved by Chamber of Deputies

On 29 October 2015, the Senate approved the Budget for 2016 which includes amendments to the Federal Tax Code and the Income Tax Law. Among others, they include a reduction of the withholding tax rate levied on interest on long-term savings, incentives (e.g. waive of penalties, granting of tax credits in view of payment of taxes abroad) for individuals to repatriate assets located abroad, provided that certain conditions are met; and new deductions related to work-related benefits.

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P E R U

Procedure to obtain information protected by Peru’s bank secrecy laws

The tax administration’s Report issued on 25 September 2015 states that, by virtue of exchange of information clauses included in tax treaties, the Peruvian tax administration is able to obtain information protected by Peru’s bank secrecy laws where such information is required by the competent authority of Peru’s treaty partner, even if the Peruvian tax administration does not need such information for its own tax purposes. The Peruvian tax administration must follow the procedure laid down by Peru’s domestic legislation.

U R U G U A Y

Budget 2015-2019 – Bill issued

The Bill of the National Budget for the years 2015 to 2019 was issued on 31 August 2015 and proposed amendments to several income tax regulations, including individual income taxes and net wealth tax, real estate transfer tax, and the tax code.

V E N E Z U E L A

Monthly minimum salary increased

A 30% increase of the monthly minimum salary introduced by a Decree on 19 October 2015, from VEF 7,421.66 to VEF 9,649 is in force as from 1 November 2015.

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A S I A - P A C I F I C

A Z E R B A I J A N

Bill introducing tax amendments – adopted by parliament

On 20 October 2015, the parliament adopted a bill introducing tax amendments in regard to individual income tax, simplified tax, value added tax and tax management. Regarding the first one, Individuals are entitled to an exemption of a subsistence minimum (AZN 146 for 2015) for monthly employment income up to AZN 2,500.

C H I N A

Administrative measures on treaty benefits for non-residents published

On 27 August 2015, the Chinese Tax Authorities issued an announcement concerning administrative measures on how non-resident companies or individuals may apply for and obtain benefits provided under tax treaties concluded by China, and it has effect as from 1 November 2015. Treaty benefits are referred to as an exemption or reduction of domestic enterprise income tax and individual income tax provided under a tax treaty. Non-resident taxpayers entitled to treaty benefits may apply for tax exemption or reduction when filing their tax returns or when the tax is withheld by a withholding agent.

I S R A E L

Extensions limited for work Permits and b-1 Visas Beyond 63 Months

Employers of foreign experts under work permits and B-1 visas can no longer extend such visas beyond 63 months. This instruction is expected to indefinitely delay pending work permit and B-1 visa extension applications. The relevant ministries are reevaluating the current extension process and further policy changes are likely.

K A Z A K H S T A N

Budget plans for 2016-2020 – approved by government

On 29 August 2015, the government approved a Protocol which announces the budget plans for the years 2016-2020. Among other amendments, the individual income tax rate (currently 10%) to 11% in 2017 and to 12% in 2018.

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Bill introducing mandatory social health insurance

On 8 October 2015, a bill introducing mandatory social health insurance contributions was sent to the Senate and it addresses a new social health insurance system to be launched from 2017. Social health insurance contributions, regarding dependant employment income, will be payable as described below:

•Employerswillwithholdandpaycontributionscalculated on the basis of employees’ salaries, at rates that will gradually increase from 2% in 2017 to 5% in 2020;

•Employeeswillpaycontributionscalculatedonthebasis of taxable employment income, at 1% in 2019 and 2% from 2020; and,

Q A T A R

National health insurance for expats from 2016

Implementation of the national health insurance scheme (Seha) for expatriates including domestic workers will begin next year through private insurance providers.

The coverage for expatriates will begin next year and private insurance providers will be responsible for that. Private insurance providers will issue their own insurance cards to expatriates, as in the existing system, while citizens will continue to use their Qatari IDs. There will be three different basic packages for expatriate workers based on their salary structure. They are broadly classified as white-collar and blue collar workers and domestic helps. Insurance for visitors will cover only emergency services.

S A U D I A R A B I A

New Resident Identity Card to Replace Iqama

Starting October 14, 2015, a new Resident Identity Card will replace the existing card, (Iqama).The new card, called Muqeem, will provide work and residency authorization and is expected to be valid for five years (instead of the Iqama’s one-year validity), renewable electronically every year.

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U Z B E K I S T A N

Foreign employees subject to social payments

On 12 October 2015, the State Tax Committee explained how social payments apply to foreign employees. They are payable by employees who are citizens of Uzbekistan; or foreign individuals permanently resident in Uzbekistan. The unified social tax is payable by resident legal entities and non-resident legal entities carrying on business activities in Uzbekistan through a permanent establishment.

Tax incentives for employment of highly qualified foreign

On 27 October 2015, the Lower Chamber of the Parliament adopted a draft law that introduces tax incentives for the employment of highly qualified foreign individuals employed in management positions. In particular, joint-stock companies do not have to pay the unified social tax with respect to such individuals. In addition, such individuals will be entitled to individual income tax incentives.

E U R O P E

B E L G I U M

Budget 2015/2016: Federal government reaches additional agreement – tax shift on employment

During a press conference of 10 October 2015, details were presented about an agreement reached by the government on the tax shift on employment. The most important measures are an increase of the withholding tax from 25% to 27% from 1 January 2016.

F R A N C E

French 2016 budget proposals – presented to Parliament

On 30 September 2015, the government presented the draft Budget for 2016 that includes, among others, the following proposals regarding the individual taxation:

•France’sproposed2016financebillincludes,among others, a transition to a ‘pay as you earn’ taxation system, under which income tax would be withheld at source starting from 1 January 2018 and that will be implemented gradually, with the foundation for the new rules laid out in the proposed finance bill for 2016.

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•Electronicfilingoftheannualincometaxreturnwouldbe phased in over a four-year period.

•Individualincometaxbracketswillbeincreasedby0.1%to account for inflation;

F I N L A N D

Budget proposal for 2016 – presented to Parliament

On 28 September 2015, the government presented its Budget proposal for 2016 to the parliament. Regarding the individual taxation:

•Theratetablefornationalincometaxleviedonearned income in 2016 has been changed (i.e.,to a taxable income from EUR 16,700 to EUR 72,300 and over applyes rates of 6.50% to 31.75%).

•Themaximumamountoftheearnedincomecreditagainst national tax on earned income is increased to EUR 1,260, the one used to calculate the credit is increased to 11.8% and the one to reduce the maximum credit is increased to 1.46%;

•Thetemporaryexpatriateregimeisextendeduntil31 December 2019;

I R E L A N D

Budget for 2016

The Budget for 2016 was presented to the parliament by the Minister for Finance on 13 October 2015. Its significant features affecting the individual taxation, which will generally apply from 1 January 2016, are summarized below:

•theUniversalSocialCharge(USC)rateswillbereduced as follows: 1.5% rate will be reduced to 1%; 3.5% rate to 3%; and 7% rate to 5.5%. Also, USC will not apply to individuals with gross income of less than EUR 13,000 (increased from EUR 12,012);

•EarnedincomecreditofEUR550isintroducedforself- employed taxpayers who derive trading or professional income, and who are not entitled to the employee tax credit on their income;

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Revenue publishes brackets and rates of Universal Social Charge

On 14 October 2015, the Revenue published the brackets and rates of the USC, which is due on gross income, including notional payments reduced with certain capital allowances. The new brackets and rates for 2016 arises to 1% to 5% for agregate income between EUR 12,012 and 51,376 and of 8% if over EUR 70,044, being lower if aged over 70 or holding a Medical card, and income lower than EUR 60,000; plus over EUR 70,044 no rate is applied. Also all individuals can apply an exemption of EUR 13,000.

I T A LY

Legislative Decree promoting growth and internationalization – details on amendments to taxation of inward expatriates

A Legislative Decree published in the Official Gazette on 22 September 2015 and into force since 7 October 2015, provides for new measures aimed at promoting the growth and internationalization of Italian companyies, amending the current tax regime available to inward expatriates. In particular:

•Thecurrentfavourabletaxregimeforinwardexpatriates has been extended to 31 December 2017 and is now also available to qualifying individuals born before 1 January 1969.

•Moreover,only70%ofemploymentincomederived individuals who transfer their residence in Italy for tax purposes will be included in taxable income, provided that certain conditions are fulfilled (i.e., the individual has been a resident of a foreign country for the 5 years preceding the transfer of residence and intends to reside in Italy for at least 2 years; the working activity is performed for an enterprise resident in Italy, following the conclusion of an employment contract with the same enterprise or a related company; the working activity is mainly performed in Italy; and the individual has a management role or fulfils high qualification or specialization requirements, to be defined by a forthcoming Ministerial Decree).

The partial exemption will then apply for the tax year in which the transfer of residence occurs and the following 4 tax years.

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Tax treatment of non-resident individuals deriving income from Italy

On 5 October 2015, a Ministerial Decree of 21 September 2015 published in the Official Gazette, issued by the Ministry of Economy and Finance, enacted implementing rules on the tax treatment of certain qualifying non-resident individuals deriving most of their income from Italian sources.

With effect from tax year 2014, non-resident individuals who are residents of an EU or EEA country that provides for an adequate exchange of information with the Italian tax authorities; and derive more than 75% of their income from Italian sources; will be taxed as Italian residents (including full allowances), subject to the condition that these non-resident individuals do not benefit from similar allowances in the state of residence. Implementing rules have been provided with regard to the full recognition of tax allowances and reliefs. In particular, qualifying non-resident individuals are required to submit to their withholding agents a specific declaration in lieu of affidavit, providing for all necessary information, e.g. the state of residence for tax purposes and, in the case of personal credits, personal data of family members. Furthermore, they must keep and submit to the Italian tax authorities a number of documents, including a copy of the tax return filed in the foreign state of residence.

N E T H E R L A N D S

Netherlands’ 2016 budget would lower labor taxes

Lowering employment taxes to boost jobs and economic growth is a key objective of the Dutch draft budget submitted to the lower house of Parliament. Employment provisions include: •Phasingoutthegeneraltaxcreditforcreditforhigh earners but raising the employment tax credit to a maximum of €3,103 ̶ up from €2,220 ̶ and reducing the second and third tax bands.

•Grantingemployersataxcreditofupto€2,000per year for each employee whose salary is at or close to the minimum wage beginning in 2017. The credit is intended to encourage the hiring of lower-paid workers.

•Increasingtheincome-indexedcombinationtaxcreditand childcare benefit.

•Increasingpaternityleavefromtwotofivedaysbeginning in 2017.

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Tax Plan 2016 – presented

On 15 September 2015, the Tax Plan 2016 was presented by the Minister of Finance to the lower house of the parliament. The most important proposals regarding income tax, which unless otherwise indicated will apply from 1 January 2016, are summarized below:

•Incometaxbrackets:thesecondbracketwillbereduced from 42% to 40.15%;

•Generaltaxcredit:themaximumamountofthegeneral tax credit will be EUR 2,230;

•Employmentcredit:whichisavailablefortaxpayerswho are employed, or undertake entrepreneurial activities, will be increased to a maximum of EUR 3,103; (currently, EUR 2,220), which is income-dependent. This credit will be zero for incomes in excess of approximately EUR 120,000;

•Seniorcitizens’credit:themaximumavailabletotaxpayers who, at the end of the relevant calendar year, have reached the official retirement age, will be EUR 1,730 for 2016 (currently, EUR 1,119);

N O R W A Y

Draft Budget for 2016 presented

On 7 October 2015, the Budget for 2016 was presented to the parliament. Details of the individual taxation measures mentioned in the Budget, which will apply from 1 January 2016 unless otherwise indicated, are summarized below:

•Thepersonalincometaxrateisreducedto25%;

•Therateofnetwealthtaxisreducedto0.8%(currently, 0.85%) and the basic allowance is increased to NOK 1.4 million (NOK 2.8 million for married couples) (currently, NOK 1.2 million and NOK 2.4 million respectively);

•Taxrulesregardingbenefitsinkind(i.e.,privateuseofthe employer’s car) simplified;

•Thresholdafterwhichexpensesrelatingtotravelling between home and place of work are deductible is increased to NOK 22,000;

•StandarddeductionforsingleparentsisincreasedtoNOK 49,800;

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•Upperlimitfortheminimumallowanceisincreasedto NOK 91,450 for employment income and to NOK 73,600 for pension income;

•Currentsurtaxonpersonalincomeisreplacedbya“step tax” with rates between 0% to 13.6% for taxable income from NOK 158,800 to NOK 909,500 and over.

R U S S I A

Proposed amendments to social security contributions

On 12 October 2015, the government submitted a draft Law to the lower chamber of the parliament, proposing amendments to the social security contributions for 2018. At present, the current Federal Law regarding the obligatory pension insurance and the current Federal Law regarding contributions to the pension fund, the social insurance fund and the medical insurance fund provide certain conditions (i.e., reduced insurance contribution at the rate of 30% comprising the contribution to the pension fund at the rate of 22%, to the social insurance fund at the rate of 2.9% or to the medical insurance fund at the rate of 5.1%; and the contribution to the pension fund at the rate of 10%) apply for the years 2014 to 2017. The draft Law proposes to extend the applicability of the reduced rates until the end of 2018.

S W E D E N

Budget for 2016

The Budget for 2016 was presented to the parliament on 21 September 2015 and its details which, unless otherwise indicated, will apply from 1 January 2016, in relation to individual taxation. Among others, they are summarized below:

•An employment income credit will be more restricted for high-income earners;

•Thethresholdforthelowertaxbracketfornationalincome tax on earned income remains at the same level as in 2015 (i.e. SEK 430,200). The threshold for the higher tax bracket is increased to SEK 625,800 (currently SEK 616,100);

•Deductibilityofcertaindonationsorcontributionsmadeto private pension schemes.

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•Pensionpaymentsmadeundersocialsecuritylegislation of foreign states (e.g. old-age pensions, surviving dependants’ pensions) will be treated as corresponding pensions paid according to Swedish social security legislation;

S W I T Z E R L A N D

Automatic exchange of information in tax matters between European Union and Switzerland approved by European Parliament

According to a press release of 27 October 2015, published by the European Union, the European Parliament approved the European Union - Switzerland Savings Directive Agreement (2015), regarding the introduction of the global standard for the automatic exchange of information in tax matters. This agreement will replace the European Union - Switzerland Savings Directive Agreement (2004) that has been in force since 2005 and will apply for all EU Member States.

U N I T E D K I N G D O M

Summer Budget 2015 – reforms to taxation of non-domiciles

On 30 September 2015, HMRC launched a consultation seeking views on proposals to legislate the announcements made in the Summer Budget 2015 on reforms to the taxation of non-domiciles. It details the proposals to restrict certain individuals from being able to claim non-domiciled status for tax purposes and seeks views on the best way to legislate the announcements. The document includes draft legislation illustrating how the new rules would work in the context of one aspect of the remittance basis for income tax and capital gains tax.

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A F R I C A

M O Z A M B I Q U E

Visa Entry Requirement and Repatriation Deposit Implemented

A new law requires foreign nationals to start working in Mozambique within 60 days of the issuance of their work visa and requires employers to pay a repatriation deposit on behalf of the foreign worker and his or her family. The new law also allows work visa holders to enter Mozambique multiple times until the end of their employment contract.

Employers must ensure that foreign workers under new work visas commence employment within 60 days of receiving their work visa. Furthermore, employers must keep records of repatriation deposits and ensure that any return requests are made within the required timeframe.

N I G E R I A

New Visa Entry Requirements

Since September, 2015, all non-Economic Community of West African States (ECOWAS) nationals holding entry visas, including business visitors and tourists, must pay an extension fee if they stay past 56 days cumulatively in a twelve-month period in Nigeria. Those staying beyond 56 days cumulatively in a twelve-month period will be considered overstayers and are subject to a penalty if they do not pay the appropriate extension fee. Temporary Work Permit holders might be included in this group depending on the interpretation and discretion of immigration authorities.

S O U T H A F R I C A

Guide on Taxation of Foreigners released

The South African Revenue Service released on 22 October 2015 a Guide on the Taxation of Foreigners Working in South Africa for the fiscal year 2014/2015. It gives some guidelnines on the overview of the South African tax System, as well as on some key income tax concepts.

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R E C E N T TA X T R E AT I E S S I G N E D

Exchange of information agreement between Andorra and Switzerland enters into force

On 27 July 2015, the Information Agreement signed between Andorra and Switzerland dated 2014 entered into force, generally applying from 1 January 2016.

Treaty between Chile and United States approved by Chilean Senate

On 1 September 2015, the Chilean Senate approved the Capital Tax Treaty dated 2010 signed between Chile and the United States.

Treaty between Oman and Spain enters into force

On 19 September 2015, the Income Tax Treat dated 2014 signed between Oman and Spain entered into force, generally applying from 19 September 2015 and for the provisions of article 26 (exchange of information) from any fiscal years in accordance with the law of the requesting State.

Protocol to treaty between Belgium and Spain approved by Spanish Council of Ministers

On 11 September 2015, the Spanish Council of Ministers approved the amending protocol, signed on 15 April 2014, to the Income and Capital Tax Treaty signed between Belgium and Spain, as amended by the 2000 protocol.

Social security agreement between China (People’s Rep.) and Spain – negotiations ongoing

According to a press release of 15 September 2015, published by the Spanish government, negotiations for a social security agreement between China (People’s Rep.) and Spain are ongoing. Previous negotiations were held in March 2012 and September 2014.

Protocol to treaty between Canada and Spain enters into force

On 12 December 2015, the amending protocol, signed on 18 November 2014, to the Income and Capital Tax Treaty signed between Canada and Spain dated 1976, will enter into force. The effective dates in Spain for withholding taxes on amounts paid or credited to non-residents: 12 December 2015; for other taxes: 1 January 2016; and for all other cases: 12 December 2015. In Canada, for withholding taxes on amounts paid or credited to non-residents: 12 December 2015; and for other taxes: 1 January 2016.

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Social security agreement between China (People’s Rep.) and Spain – negotiations ongoing

According to a press release of 15 September 2015, published by the Spanish government, negotiations for a social security agreement between China (People’s Rep.) and Spain are ongoing. Previous negotiations were held in March 2012 and September 2014.

Protocol to treaty between Canada and Spain enters into force

On 12 December 2015, the amending protocol, signed on 18 November 2014, to the Income and Capital Tax Treaty signed between Canada and Spain dated 1976, will enter into force. The effective dates in Spain for withholding taxes on amounts paid or credited to non-residents: 12 December 2015; for other taxes: 1 January 2016; and for all other cases: 12 December 2015. In Canada, for withholding taxes on amounts paid or credited to non-residents: 12 December 2015; and for other taxes: 1 January 2016.

Protocol to tax agreement between China (People’s Rep.) and Hong Kong gazetted by Hong Kong

The Hong Kong Chief Executive in Council has issued an Order to implement the amending protocol, signed on 1 April 2015, to the China (People’s Rep.) - Hong Kong Income Tax Agreement (2006), as amended by the 2008 and 2010 protocols. The amending protocol will take effect after both states have completed their ratification procedures.

Tax agreement between Colombia and Panama – negotiations ongoing

According to a press release of 1 October 2015, published by the government of Colombia, Colombia and Panama have agreed to extend the ongoing negotiations for an agreement for tax matters by 60 days, in order to finalize some open issues and to determine the exact scope. The negotiations started in the autumn of 2014 and five additional rounds have been held since.

Removal of Panama from Colombia’s tax havens list – term extended

On 1 October 2015, the Ministry of Treasury of Colombia announced an extension of the 1-year term agreed with the Government of Panama in October 2014 for the conclusion of a tax treaty between Colombia and Panama, which expired on 30 September 2015. The conclusion of this treaty was the Colombian government’s precondition for removing Panama from Colombia’s tax havens list.

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Social security agreement between Spain and Ukraine authorization for signature by Spain

On 9 October 2015, the Spanish Council of Ministers authorized the signing of a new social security agreement between Spain and Ukraine. Once signed, in force and effective, the new agreement will replace the one signed on 1996.

Treaty between Finland and Spain initialled

Finland and Spain initialled a tax treaty on 24 March 2015. Once signed, in force and effective, the new treaty will replace the Income and Capital Tax Treaty of 1970, as amended by the 1970, 1973 and 1990 exchange of notes.

Treaty between Andorra and Spain approved by Andorra

On 24 September 2015, the general council of Andorra approved the Income and Capital Tax Treaty signed between Andorra and Spain of 2015.

Treaty between Germany and Netherlands enters into force

On 1 December 2015, the Income and Capital Tax Treaty signed between Germany and the Netherlands of 2012 will enter into force. The treaty generally applies from 1 January 2016. From this date, the new treaty generally replaces the one of 1959, as amended by the 1980, 1991 and 2004 protocols.

This document is a compilation of legal information drawn up by Mercer Consulting, S.L.U.. Its content is strictly confidential and has been prepared for information purposes. The information and remarks set

out in this document are therefore to be used exclusively by the person or persons for whom they have been drawn up and they may not be disclosed to third parties, whether in whole or in part, without the

prior express consent of Mercer Consulting, S.L.U., in the interest of avoiding any incorrect or unauthorized use of the information contained herein.

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