4 Mar 2010 Administrative Guidelines Provide for Safe Harbors under Which Interest paid by a French tax resident in jurisdictions that do not cooperate with rate of such withholding tax would be 25%, or lower under an applicable tax  The LRBA (Limited Recourse Borrowing Arrangement) interest rate for SMSFs under the ATO’s safe harbour rules for the 2018/2019 financial year, for real property, is 5.80%. For listed shares or units the interest rate is 7.80%. interest rate limitation (for interest payments to related parties, maximum rate set forth by Section 39-1-3 of the French tax code) a safe-harbor provision allows an additional deduction equal to 75% of the net financial expenses not deducted pursuant to the above limitation. Thus, the entity’s equity-to-assets ratio must remain equal to The 2019/20 LRBA safe harbour interest rates are up slightly compared to recent years. The LRBA safe harbour interest rate for 2019/20 for real property is 5.94%, up somewhat from the 5.80% for 2018/19. The rules relating to the maximum tax deductible interest rate applicable to interest paid to direct shareholders—for financial years closed on 31 December 2018, the interest rate released by the French tax authorities is 1.47% (keeping in mind that a higher arm’s length rate may be applied under conditions) The portion of interest payments exceeding the following rates is generally not deductible unless documentation is provided demonstrating that the interest rate applied is at arm’s length. The period in which the fiscal year ends and the applicable rates are as follows: Between 30 June 2018 and 30 July 2018 – 1.56%

interest rate limitation (for interest payments to related parties, maximum rate set forth by Section 39-1-3 of the French tax code) a safe-harbor provision allows an additional deduction equal to 75% of the net financial expenses not deducted pursuant to the above limitation. Thus, the entity’s equity-to-assets ratio must remain equal to

loans in Swiss francs, the minimum interest rate for loans in Swiss francs has to be considered. If such loans are re-financed with debt, an interest margin of 0.50% must be realized and the applied interest rate may not be below the respective minimum interest rate published by the SFTA (see table below). EUR 44,408for the 201 7 calendar year). The rate of the CICE is 7% of the total amount paid as from 1 January 2017. Payment of the CICE can be offset against the corporate income tax liability for three years, with any excess reimbursed by the French tax authorities (as in the case of the R&D tax credit). Sixteen countries have a total of 23 safe harbours. 35% of such safe harbours are “exemption from transfer pricing rules/adjustment”; “Simplified transfer pricing method” and “safe harbour arm‟s length range/rate” both account for 26% of them; and “safe harbour interest rate” accounts for 13 %.

loans in Swiss francs, the minimum interest rate for loans in Swiss francs has to be considered. If such loans are re-financed with debt, an interest margin of 0.50% must be realized and the applied interest rate may not be below the respective minimum interest rate published by the SFTA (see table below).

The FHWA's test and evaluation pilot used a nationwide Safe Harbor indirect cost rate of 110 percent of a firm's direct salary rate. This rate provided a minimal risk to contracting agencies for overpayment to those consulting firms participating in the program. Based on FHWA's experience with this pilot,

The portion of interest payments exceeding the following rates is generally not deductible unless documentation is provided demonstrating that the interest rate applied is at arm’s length. The period in which the fiscal year ends and the applicable rates are as follows: Between 30 June 2018 and 30 July 2018 – 1.56%

loans in Swiss francs, the minimum interest rate for loans in Swiss francs has to be considered. If such loans are re-financed with debt, an interest margin of 0.50% must be realized and the applied interest rate may not be below the respective minimum interest rate published by the SFTA (see table below). EUR 44,408for the 201 7 calendar year). The rate of the CICE is 7% of the total amount paid as from 1 January 2017. Payment of the CICE can be offset against the corporate income tax liability for three years, with any excess reimbursed by the French tax authorities (as in the case of the R&D tax credit).

4 Mar 2010 Administrative Guidelines Provide for Safe Harbors under Which Interest paid by a French tax resident in jurisdictions that do not cooperate with rate of such withholding tax would be 25%, or lower under an applicable tax 

The portion of interest payments exceeding the following rates is generally not deductible unless documentation is provided demonstrating that the interest rate applied is at arm’s length. The period in which the fiscal year ends and the applicable rates are as follows: Between 30 June 2018 and 30 July 2018 – 1.56% loans in Swiss francs, the minimum interest rate for loans in Swiss francs has to be considered. If such loans are re-financed with debt, an interest margin of 0.50% must be realized and the applied interest rate may not be below the respective minimum interest rate published by the SFTA (see table below). EUR 44,408for the 201 7 calendar year). The rate of the CICE is 7% of the total amount paid as from 1 January 2017. Payment of the CICE can be offset against the corporate income tax liability for three years, with any excess reimbursed by the French tax authorities (as in the case of the R&D tax credit). Sixteen countries have a total of 23 safe harbours. 35% of such safe harbours are “exemption from transfer pricing rules/adjustment”; “Simplified transfer pricing method” and “safe harbour arm‟s length range/rate” both account for 26% of them; and “safe harbour interest rate” accounts for 13 %. Almost 35% of safe harbours identifi ed are exemption from transfer pricing rules/adjustments, simplifi ed transfer pricing method and safe harbour arm’s length range/ rate are followed by 26%, and safe harbour interest rate (arm’s length rate) is followed by 13%.

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