Tax Treaty Summary

China - Barbados Tax Treaty – Once in effect, the protocol signed 10 February 2010 provides that the current 5% dividend withholding tax rate levied under the treaty by China will be available only to beneficial owners that are companies owning 25% or more of the equity interests of the Chinese company paying the dividend. Where the 25% ownership level is not met, a 10% tax rate will apply.

Finland - India Tax Treaty – Once in effect, tax treaty signed 15 January 2010 provides for a withholding tax rate of 10% on dividends, interest, royalties and fees for technical services.

Finland - Poland Tax Treaty – The 2009 tax treaty entered into force 11 March 2010 and will apply as from 1 January 2011. Once in effect, a 5% withholding tax rate will apply on dividends paid to a company (other than a partnership) that holds directly at least 25% of the payer, and a 15% tax rate in all other cases. Interest and royalties will be taxed at a rate not to exceed 5%.

Germany - Malaysia Tax Treaty – the tax treaty signed 23 February 2010 provides that a 5% withholding tax rate will apply on dividends if the beneficial owner is a company (other than a partnership) that holds directly at least 10% of the distributing company's capital; otherwise tax rate will be 15%. Interest will be subject to withholding tax rate at 10% and a 7% tax rate will apply to royalties and fees for technical services.

Germany - Syria Tax Treaty – Once in effect, the treaty signed 17 February 2010 provides for a 5% withholding tax rate on dividends paid to a company that holds directly at least 10% of the capital of the payer; otherwise, the tax rate will be 10%. Interest will be taxed at a rate not to exceed 10%. Royalties will be subject to a 12% tax rate.

Hong Kong - Brunei Tax Treaty – the tax treaty signed 22 March 2010 provides that dividends will be taxable only by the residence state. The withholding tax rate will be 5% on interest received by a bank or financial institution, and 10% in all other cases. Royalties will be subject to a tax rate not to exceed 5%.

Hong Kong - Indonesia Tax Treaty – Once in effect, the treaty signed 23 March 2010 provides for a 5% withholding tax on dividends paid to a company (other than a partnership) that holds at least 25% of the capital of the payer company; the rate in all other cases will be 10%. Interest will generally be subject to a 10% tax rate, with a 5% tax rate on royalties.

Hong Kong - Netherlands Tax Treaty – Once in effect, the tax treaty signed 22 March 2010 provides for a 0% tax rate on dividends paid to a company that holds at least 10% of the share capital of the payer company, as well as dividends received by banks and insurance companies, pension funds, headquarter companies and other qualifying entities. Tax rate in all other cases will be 10%. Interest will be taxable only by the residence state. Royalties will be subject to a rate not to exceed 3%.

Korea - Latvia Tax Treaty – The 2008 tax treaty entered into force 26 December 2009 and generally applies as from 1 January 2010. Under the treaty, dividends are subject to withholding tax at a rate of 5% if paid to a company (other than a partnership) that holds directly at least 25% of the capital of the company paying the dividends. Otherwise, tax rate is 10%. Tax rate on interest is 10%. Royalties paid in respect of industrial, commercial and scientific equipment are subject to a 5% withholding tax and 10% in all other cases.

Netherlands - Switzerland Tax Treaty – Once in effect, tax treaty signed 26 February 2010 (to replace the 1951 treaty) provides for a 15% withholding tax rate on dividends, with exemptions available for dividends received by pension funds, the Swiss social security scheme or a company that is a resident of the other contracting state and directly holds at least 10% of the paying company's capital. Interest and royalties would be tax exempt.

Russia - Botswana Tax Treaty – The 2003 tax treaty entered into force 23 December 2009 and generally applies in Russia as from 1 January 2010 (as from 1 July 2010 in Botswana). A 5% withholding tax rate applies on dividends paid to a company that holds at least 25% of the capital of the payer company; otherwise, the tax rate is 10%. Tax rate on interest and royalties is 10%.

Russia - Saudi Arabia Tax Treaty – The 2007 tax treaty entered into force 1 February 2010 and will generally apply as from 1 January 2011. Once in effect, dividends and interest will be taxed at a withholding tax rate of 5%, and royalties at 10%.