About EY Almanac

1 2016 Shipping Industry Almanac 2016EY | Assurance | Tax | Transactions | Advisory About EY EY is a global leader in assurance, tax, transaction and advisory services. The insights and quality services we deliver help build trust and confidence in the capital markets and in economies the world over. We develop outstanding leaders who team to deliver on our promises to all of our stakeholders. In so doing, we play a critical role in building a better working world for our people, for our clients and for our communities. EY refers to the global organization, and may refer to one or more, of the member firms of Ernst & Young Global Limited, each of which is a separate legal entity.

2 Ernst & Young Global Limited, a UK company limited by guarantee, does not provide services to clients. For more information About our organization, please visit 2016 EYGM LimitedAll Rights Reserved. EYG No. XXXXXED Shipping IndustryAlmanacShipping Industry Almanac 2016 Shipping IndustryAlmanac2016 About EYEY is a global leader in assurance, tax, transaction and advisory services. The insights and quality services we deliver help build trust and confidence in the capital markets and in economies the world over. We develop outstanding leaders who team to deliver on our promises to all of our stakeholders.

3 In so doing, we play a critical role in building a better working world for our people, for our clients and for our refers to the global organization, and may refer to one or more, of the member firms of Ernst &Young Global Limited, each of which is a separate legal entity. Ernst & Young Global Limited, a UK company limited by guarantee, does not provide services to clients. For more information About our organization, please visit 2016 EYAll Rights of contentsIntroduction iArgentina1 Australia11 Barbados29 Belgium35 Brazil55 Canada75 China93 Croatia107 Cura ao113 Cyprus119 Denmark125 Dominican Republic133 Estonia145 Finland153 France159 Germany169 Greece181 Hong Kong193 India201 Indonesia213 Ireland223 Isle of Man233 Italy243 Japan251 Luxembourg257 Malaysia271 Malta279 Mexico289 The Netherlands297 New Zealand309 Norway317 Oman329 Panama339 Philippines357 Poland 381 Portugal387 Romania393 Russia397 Singapore411 South Africa421 Spain431 Sri

4 Lanka439 Sweden445 Taiwan449 Thailand457 Turkey465 United Arab Emirates475 United Kingdom483 United States of America497EY global shipping industry network503 Shipping Industry Almanac 2016 Shipping Industry Almanac 2016 Shipping Industry Almanac 2016 The Shipping Industry Almanac is published annually by the EY global shipping industry network, which comprises shipping industry professionals in over more than 60 EY member firms. Our 19th edition of the Shipping Industry Almanac provides you with a comprehensive summary of the local shipping industry infrastructure and regulatory, corporate and tax environments in 49 jurisdictions around the world.

5 The content is based on information current as of 1 January 2016, unless otherwise indicated. A directory of EY shipping industry executives across our four service lines of Assurance, Tax, Transactions and Advisory is at the back of the Shipping Industry Almanac , and highlights our local industry knowledge and our global more information, please visit us at or contact any of our professionals listed in the Industry Almanac 20161 Argentina1. TaxArgentina does not have a specific tax law for shipping companies. Shipping companies must comply with general tax regulations.

6 In Argentina, companies are subject to federal taxes (such as income tax and value-added tax (VAT), among others), provincial taxes (such as turnover tax and stamp tax) and municipal taxes. However, some guidance regarding shipping activity may be found in the federal and provincial legal Income taxFor Argentine residents, income tax is levied on all income earned in Argentina or abroad. Income tax paid on income from activities abroad may be claimed as a tax credit. For nonresidents and foreign beneficiaries, income tax is levied exclusively on Argentine-source income.

7 Nonresidents become residents if they have a permanent establishment in general, Argentine-source income arises from assets located, placed or used in Argentina, from the performance of any act or activity in Argentina and from events occurring within Argentina. The income tax rate is 35% and is applicable to the net income of companies residing in Argentina and the net presumed income of foreign beneficiaries (in some cases, net-income basis applies).The following items may be deducted from gross income to assess taxable income: In general, all expenses necessary to earn it or to maintain and keep its source The amortization or depreciation of construction, equipment and other assets, in general, based on their estimated useful life The net operating losses (NOLs) from previous fiscal years (carryforward is allowed for five years.)

8 There is no carryback system)The Income Tax Law has many specific requirements regarding tax deductions for foreign loans when the lender is a related 18 of the Income Tax Law establishes the timing of the deduction of interest on foreign intercompany loans (also applicable to other expenses that are considered as Argentine source income for the foreign beneficiary). Interest derived from loans granted by foreign related parties or from tax havens ( noncooperative countries) may only be deducted in the same tax year the payments are made or in the period of accrual, but only if actual payment takes place before the due date for filing the tax return for the tax year in the lender is not a related company, then the deduction of interest is allowed on an accrual basis.

9 If the lender is a related party, thin capitalization rules must also be capitalization rules are applicable when interest is paid to a foreign lender that controls the Argentine borrower company, except for those cases when interest payments are withheld at 35%. Interest paid where the liabilities exceed two times the amount of the company s equity at year-end becomes nondeductible and is taxed like dividends. In other words, the excess interest will become a permanent difference between the book and tax pricing rules follow Organisation for Economic Co-operation and Development (OECD) guidelines and apply on transactions with related parties or with entities in tax havens ( , noncooperative countries).

10 Additionally, there is no tax consolidation system in paid in excess of net income, which are assessed using the general provisions of the Income Tax Law and accumulate as of the prior fiscal year-end through the date of payment, are subject to a 35% withholding rate. The 35% rate may be reduced if the foreign beneficiary is a resident of a country with which Argentina has entered into a double-taxation agreement, as long as applicable treaty requirements are met. Per the last Income Tax Law modification (September 2013), dividend distribution is taxed in Argentina at Shipping Industry Almanac 2016 Shipping Industry Almanac 20162 Argentinaa rate of 10% when the payment is made by a local company to a foreign company or individual, or to local from the sale of shares of an Argentine company owned by a foreign shareholder are taxed at a 15% rate.