Exhibit 99.9(c)(vii)
November 2023
AMENDED
Annex I to Schedule VII to
Securities Lending Agency Agreement
Summary of Minimum Manufactured Dividend Requirements (Tax Matrix)
Lender Name: HC Capital Trust
The following Matrix provides the minimum manufactured dividend requirements for the client (including any tax reclaim). The Matrix is based on the assumption that all relevant documentation is in place and where applicable the beneficial owner can benefit from the relevant double tax treaty ('DTT') in place.
| Argentina | 93% |
| Australia (Franked) | 100% |
| Australia (Unfranked) (Note 1) | 85% |
| Austria | 85% |
| Belgium | 85% |
| Brazil | 100% |
| Canada | 85% |
| China H Shares | 90% |
| Czech Republic | 85% |
| Denmark | 85% |
| Finland | 85% |
| France | 85% |
| Germany | 85% |
| Greece | 95% |
| Greece (REIT) | 100% |
| Hong Kong | 100% |
| Hungary | 100% |
| Ireland | 100% |
| Ireland (REIT) | 85% |
| Israel | 75% |
| Israel (REIT) | 77% |
| Italy | 85% |
| Korea (South) | 78% |
| Japan | 90% |
| Luxembourg | 85% |
| Mexico | 90% |
| Mexico (REIT) | 70% |
| Netherlands | 85% |
| New Zealand (Franked) | 85% |
| New Zealand (Unfranked) | 85% |
| Norway | 70% |
| Philippines | 75% |
| Philippines (REIT) | 90% |
| Poland | 85% |
| Poland (ADR) | 81% |
| Portugal | 85% |
November 2023
| Singapore | 100% |
| Singapore (REIT) | 90% |
| South Africa | 85% |
| Spain | 85% |
| Sweden | 85% |
| Switzerland | 85% |
| Thailand | 90% |
| Turkey | 90% |
| Turkey (REIT) | 100% |
| United Kingdom | 100% |
| United Kingdom (REIT) | 85% |
| United States | 100% |
Notes to the Matrix
| (i) | General assumptions: The following general assumptions are made in respect of the lender of the securities. |
| (1) | Lenders are portfolio investors in equities (which as a general rule, implies a holding of less than 10% of the issued share capital of the investment company); |
| (2) | The lender of securities is able to benefit from the relevant DTT (if available); | |
| (3) | The lender of securities has all requisite documentation in place to benefit from both local domestic reductions/exemptions and from all DTT reductions/exemptions (if applicable). |
| (ii) | Country specific assumptions/notes |
| (1) | Australia |
No withholding tax applies to fully imputed (franked) dividends. Unfranked dividends attract withholding tax at the rate of 30% on the unfranked portion or as reduced u nder a DTT. Partially franked dividends can attract different rates of withholding tax depending on the portion of dividend franked.
| (2) | Singapore |
There is no withholding tax on Singapore dividends. Effective 1 January 2003, Singapore moved from an imputation system ("franking system") to a "one-tier" system in which dividends are subject to a final tax at the corporate level and are exempt from further tax in the hands of resident and non-resident shareholders.
November 2023
| (3) | United Kingdom |
There is no withholding tax on United Kingdom dividends. A tax credit equal to 10% of the sum of the dividend plus the tax credit (or I/9th of net dividend) applies to all dividends paid. There is no refund of the tax credit available. The above assumes that the securities lender does not control directly or indirectly, at least 10% of the voting power in the company paying the dividends.
Agreed by Client:/s/ Mark Hausmann
Date: 11/9/2023
Important - Disclaimer
The Securities Finance Matrix (the Matrix) and the associated notes have been compiled by the Citigroup Corporate Tax Department. The Matrix and notes are provided as a guide to the minimum manufactured dividend/interest coupon requirements (as the case may be) for a holder of securities wishing to lend securities to another person (the counter-party). In every case we stress the need for clients to obtain specific tax advice. The information contained herein should under no circumstances be relied upon and readers should not make investment decisions based on the information provided herein. Whilst every effort has been made to independently verify each rate in the Matrix and each statement made in the notes, Citigroup or any of its subsidiaries or affiliates accept no responsibility of the accuracy or completeness of the information contained herein. The Matrix and notes were assembled at time of signing and, unless otherwise indicated, are based on information available at that time.
IRS Circular 230 Disclosure: Citigroup, Inc., its affiliates, and its employees are not in the business of providing tax or legal advice to any taxpayer outside of Citigroup. Inc. and its affiliates. This email and any attachments are not intended or written to be used, and cannot be used or relied upon, by any such taxpayer for the purpose of avoiding tax penalties. Any such taxpayer should seek advice based on the taxpayer's particular circumstances from an independent tax advisor.
