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Navigating new
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Mobile Employees
International Assignment Services
Taxation of International Assignees
Country – Panama

Human
Resources Services

International
Assignment
Taxation Folio
Last Updated: May 2015
This document was not intended or written to be used, and it cannot be used, for the purpose of Menu
avoiding tax penalties that may be imposed on the taxpayer.
Country:
Panama

Introduction: International assignees working in the Republic 4


of Panama
Step 1: Understanding basic principles 5
Step 2: Understanding the Panama’s tax system 7
Step 3: What to do before you arrive in the Republic of 12
Panama
Step 4: What to do when you arrive in the Republic of 14
Panama
Step 5: What to do at the end of the year 15
Step 6: What to do when you leave the Republic of 17
Panama
Step 7: Other matters requiring consideration 18
Appendix A: Tax rates for individuals 19
Appendix B: Individual tax calculation 20
Appendix C: Principal IAS contacts 21

Additional Country Folios can be located at the following website:


Global Mobility Country Guides

International Assignment Taxation Folio 3


Introduction:
International assignees working in the
Republic of Panama
This booklet was prepared by Familiarity with these issues will make without much prior notice.
PricewaterhouseCoopers to provide your assignment easier and more This booklet will give you the
foreign nationals planning to work in enjoyable. preliminary information you
the Republic of Panama with a general can use to define the issues
background of Panama tax law and This booklet is not intended to be a that are relevant for your
other relevant issues. It reflects tax law comprehensive and exhaustive study situation.
and practice as of July 2013. of Panama's tax law, but should be
used as a guide as you prepare for your If we can be of assistance
This booklet traces a Panamanian assignment in the Republic of Panama. please contact us, a list of
assignment through seven steps. These We should advise you against making contacts can be found in
steps address the specifics of what to any decisions without first seeking Appendix C.
do before you arrive in the Republic of professional advice, as laws and
Panama, what to do when you are interpretations in the Republic of
here, and what to do before you move Panama are still, to some extent,
out of the Republic of Panama. subject to relatively frequent changes

4 Human Resources Services


Step 1:
Understanding basic principles
The scope of Panamanian Determination of residency tax established by the Law
taxation No. 8 of March 15th of 2010.
3. The term residency refers to a
1. Taxable income produced person physically located and For residents, the
from any source within the generating income in Educational Insurance Tax is
territory of Panama, Panama, for more than 183 assessed at the rate of 1.25%
regardless of where it is days, being continued or on salaries and wages paid by
received, is subject to income rollover in the same fiscal the employer.
tax. Income tax is levied only year. Contrariwise, non-
upon net income derived residency refers to persons 6. Both residents and
from operations within located in Panama and nonresidents are subjects to
Panama, by individuals and generating income, for less pay the Social Security Tax
corporations, except those than 183 (continued or which is assessed at a rate of
considered as non-taxable or rollover in the same fiscal 9.75%.
exempt by law, in accordance year). Method of calculating
to the corporate and personal income tax
income tax rates. 4. Nonresidents are taxed on
gross income produced from
7. There are two different ways
In this sense, income derived Panamanian sources at a rate
to calculate the income tax,
from activities performed of 15%, plus a 2.75% one is when the person is an
abroad Panama is not Educational Insurance Tax.
employee, in which the
considered taxable, although Taxes arising from
employer is responsible to
it may be subject to dividend Panamanian salaries will be withhold the corresponding
tax or withholding tax, in withheld by the payer, if all
taxes in attention to
cases where these activities compensation is subject to
progressive rates, and the
benefit o generate taxable withholding and all taxes are other one is when the person
income to individuals or withheld by employer, the
is an independent contractor,
companies, nationals or individual is not required to
a person with more than one
foreigners located in Panama. file an annual income tax job or an employee that has
return.
The tax year another kind of income
5. Residents are taxed on distinct from the
2. For purpose of the annual net taxable income (gross employment, in which case
tax, fiscal period begins on income – deductible the filing of an annual income
January 1st and ends as of allowances) earned from tax return is required.
December 31st of each year, Panamanian sources, in
so filing must be completed 8. Panamanian law establishes
accordance to the new rates
on a calendar year basis. that in cases where the
for the calculation of income
taxpayer has only one source

International Assignment Taxation Folio 5


of income related to an 9. It is important to mention 10. Progressive tax rates are then
employment, he/she may file that employment income will applicable to the annual
an annual income tax return. not be subject to deductions income obtained in order to
In the annual income tax related to the generation of determine the taxes the
return the taxpayer may taxable income or to preserve employee must pay (See
deduct any expenses incurred the income source; which Appendix A for applicable
within the fiscal year that are means that no losses arising rates).
expressly determined by the from capital, rental or other
law. The result after applying sources will be allowed
the corresponding deductions against employment income.
will constitute the annual tax These type of tax deductions
base. may proceed only in case of
freelance income.

6 Human Resources Services


Step 2:
Understanding the Panama’s tax system
Taxable income Income from independent 20% rate. Withholding tax on
11. Taxable income under the services dividends is applied to
Panamanian tax legislation 13. Independent consultants and residents and nonresidents in
includes the following: other self-employed the same terms.
individuals will be taxed for The entity paying the income
– Income from the activities that generate
dependent services to the individual will
taxable income within the
(employment); withhold the corresponding
Republic of Panama; these taxes, and this will constitute
are the related to services
– Income from the final tax liability on such
rendered or used in the
independent services income.
(independent country. In general, any
expense required to obtain, 15. Dividends received from
contractor);
ensure and maintain the foreign sources or derived
– Income from taxpayer income, as well as from entities located abroad
dividends; the services provided abroad (not performing activities
to Panamanian tax residents within the Panamanian
– Income on the sale of that consider the expense as territory) are not subject to
real estate; and deductible. payment of taxes in Panama.
– Other income. Deductible expenses are the Income from the sale of real
Employment income
costs and expenses incurred estate
for the generation of
12. This group of income 16. The sale of real estate located
Panamanian source income
in Panama is subject to
includes remuneration or its conservation, as long as income tax and property
generated from employment, they are duly supported and
which can be defined as all transfer tax. The looses and
subject to the corresponding
gains related to the sale of
remuneration, whether withholdings if applicable. real estate are not considered
monetary or non-monetary,
and benefits in kind provided Income from dividends to determine income tax
generated during the year,
to an employee or to one of 14. Shareholders pay dividend from other incomes obtained
his/hers family member. The tax at a rate of 10% or 5%,
location of payment of by the tax resident.
depending on the source of
salaries, bonuses etc., will not the income, through a 17. The property transfer tax is
affect the tax treatment. definitive withholding made calculated to a 2% rate on the
by the entity distributing the tax basis, which is
dividend. Dividends on determined by the amount
bearer shares are subject to a that results higher from

International Assignment Taxation Folio 7


calculate: the sale Price of transfer tax and also to an services rendered
property or the value of the income tax payment outside of Panama; and
property registered at the determine in accordance to
Public Registry plus a the following rates: if the – Income not produced
surcharge of 5% for each value of the property is up to within the Panamanian
twelve (12) months period of $35,000.00 the tax rate will territory.
ownership. be of 0.50%; if the value is
21. There are also items exempt
between $35,001.00 and $
18. Since the year 2009, the law from income tax in Panama,
80,000.00 the tax rate will be such as:
49 established that income 1.50%; if the value is greater
tax will be paid in advance by than $80,000.00 the tax rate – Interest and gains on
the buyer at a rate of 3% on will be of 2.50%; and if the sales of government
the gross income obtained transfer is referred to new securities;
from the transaction. This is commercial places the
applicable for taxpayers that applicable income tax rate – Gains on sales of
do not sell more than 10 will be of 4.50%. This is going stocks, bonds and
properties within a tax year to be calculated over the other securities issued
(not frequent sellers). value expressed in the Public by entities registered
However, the seller has the Registry or the price of the with the National
right to prepare a special tax transaction (whichever Securities Commission;
return to calculate the income results higher). and
at a 10% rate over the gains,
or what is the same, over the Other income – Interest on saving
amount resulting from the accounts and short or
20. The following are considered
difference between the value long term deposits with
foreign source incomes as
determined at the Property banks.
they are not produced or used
Registry or the book value, in Panama teritory, therefore Taxation of employment
(whichever lower), and the they are not taxable under the income
sale price. If the difference Panamanian Income Tax
between the advanced tax 22. The Panamanian tax system
Law:
payment made on the gross is strictly territorial;
value and the tax paid on the – Gains on sales of therefore, foreigners and
net value of the real estate, shares and securities of nationals are taxed only on
results in a favorable amount Panamanian income produced within
for the taxpayer, it is possible companies exclusively Panama by the same rules,
to request the credit engaged in activities regardless of where payment
generated form the tax paid outside Panama; comes from, although there
in excess. are differences between
– Income for leasing resident and nonresident
19. If the taxpayer sells more contracts from taxpayers.
than ten (10) properties properties located
within a tax year (frequent abroad; 23. A nonresident foreigner
seller), the capital gain on the staying in Panama for 183
transfer of properties will be – Income from offshore days or less is subject to
subject to the property or foreign trust, income tax, educational
insurance and social security

8 Human Resources Services


when working as an mandatory to apply WHT entitled to an annual
employee; the taxes will be over the fringe benefits paid, deduction of US$800;
calculated according to a in concepto of income tax as
combined income tax rate. well as social security – Medical Expenses
This will apply for employees contributions. incurred on his behalf
of national or foreign or for his dependents,
companies. Transportation and within the Republic of
lodging Panama. It will be
24. When the person is an 29. Transportation and lodging necessary to prove
independent contractor and expenses will be deductible through invoices or
stays for less than 183 days, whether incurred locally or other documentation
the tax rate will be of 15% on abroad if they are related to the expenses incurred,
the income tax. the activities performed by including the
the company. The allowable hospitalization and
25. The employee or the medical attention
independent contractor will expenses normally include
travel and lodging for insurance premium;
also be subject to the
employees based in one point
educational insurance tax – Interests paid on
which is for the nonresidents in Panama to another place in mortgage loans or
Panama or to a place abroad
of 2.75% and for residents loans addressed to
in pursuit of business. Travel
1.25%. make home
and lodging expenses improvements, for
26. Only employees incurred in Panama for
properties localted in
(nonresidents or residents), expatriates living in Panama
Panama up to US$
are subject to pay the Social are non deductible for the 15,000 per year;
Security which is assessed at individual.
a rate of 9.75% on wages and – Interest paid on
30. Excessive or unrelated
other compensation paid. educational loans;
expenses can be objected by
Territoriality principle the tax authorities. – Donations to local
27. Nonresidents as well as educational and
Tax deductions charitable institutions,
residents will only be taxed
31. Resident taxpayers will be if these institutions
on the income generated or
subject to the normal tax have been duly
derived from services
rendered within the Republic rates on their net income authorized by the tax
arising from Panamanian administration to
of Panama, regardless of
sources. Panamanian receive such donations.
where the payment is
received. legislation allows the The deduction is
following personal allowed up to an
Benefits in kind deductions and expenses for amount of US$50,000
28. Taxable income includes individuals that are residents per year;
and have incomes obtained
employment income and – Contributions to
from salaries:
benefits in kind, such as
private retirement
housing, taxes, school, car Married couples filing
– funds which are
allowances, insurance, etc. a jointly tax return are incorporated in
According to the law it is

International Assignment Taxation Folio 9


accordance to Law No. using the figure of exempt from social security
10 of 1983, up to the representation expenses. This and educational insurance
10% of the annual payment is 100% deductible taxes if do not exceed a
gross income of the for the company. This monthly salary.
taxpayer or up to a amount is included in the
maximum annual employee's taxable income. Payroll withholding tax
amount of USD15, However, it is subject to a 37. Income tax should be
000.00, whichever special WHT rate of 10%, if withheld by the employer on
results less. the annual payment of this a monthly basis, from
retribution goes up to employment income paid to
Company cars USD25, 000; in case the the following individuals:
32. In accordance with representation expenses
Panamanian law, the cost of exceeds USD25,000, the tax – All employees of a
providing a company car to will be calculated as follows: Panamanian or foreign
an employee is considered as USD2,500 for the first company generating
taxable income for the USD25,000, and a 15% rate income in Panama,
individual if the local entity over the exceeding amount. including expatriates
deducts the expense related assigned to work at the
with depreciation, 35. The split portion of the company; and
maintenance, insurances, etc. representation expenses
should not exceed the 100% – All employees of a
Law establishes that 70% of permanent
expenses will be considered of the salary split portion,
this in accordance to the establishment in
as taxable income for the
amendment of our Tax Law Panama.
employee.
by means of Executive Decree 38. Since 2006, foreigners that
For social security 98 of 2010. It also establishes
hold a Special Temporary
contributions, is applicable that the representation
Visitor VISA or a
the same rule regarding the expenses should be paid to Multiregional Headquarter
70% of taxability. high profile or trustworthy
Visa (SEM visa) are exempted
employees, although this
If the employer doesn’t to pay income tax and Social
concept is not very well Security Contributions, if the
deduct the car expense, the defined.
employee benefit is salary payments come
considered non-taxable. The representation expenses directly from its Head
are totally subject to social Quarter, located abroad and
Housing benefit security contributions. the activities of the company
33. This benefit is taxable if the in Panama have an exclusive
employee is provided with an The employee that receives regional or international
allowance for housing or a this type of compensation will character.
reimbursement of his/her have the option to file an
annual income tax return. 39. The taxes will be withheld by
housing costs. the employer and should be
Representation Expenses Christmas bonus paid to the Panama tax
36. Under Panamanian Social authorities. The employer is
34. Employers often split the obliged to have a payroll and
salary of their employees Security law, some special
Christmas bonuses are is responsible for the

10 Human Resources Services


registration of the Company
before the tax administration
and the correct payment of
the taxes.

40. If payroll withholding is not


performed – for instance if
the expatriate works at a
company considered as
permanent establishment –
then the employee is
personally responsible for
reporting the incomes that
are subject to Panamanian
tax through an annual
income tax return, and also of
paying the corresponding
taxes.

International Assignment Taxation Folio 11


Step 3:
What to do before you arrive in the
Republic of Panama
Entry and departure Security Office, with a few 48. In Panama at least 90%
formalities exceptions on certain types of percent of the workers in
migratory permits (SEM and every commercial or
41. A valid passport is necessary Temporary Resident) industrial corporation must
for expatriates entering into be Panamanian or certain
the country. On the other Work permit specified foreigners, as
hand, Panama has suscribed 44. All foreigners who intend to foreigners married with
agreements with some work in Panama must obtain Panamanians or foreigners
countries in order to a work permit. This with ten years of residency in
eliminate the requirement of requirement strictly applies Panama. Ninety percent of
entry visas for passport even for short term the total wages and salaries
holders from these countries. assignments to Panama. must be paid to Panamanians
and the mentioned
42. Expatriates who do require a 45. The work permit is not issued foreigners. In the specific
visa to enter in the Republic with a tourist visa, the
of Panama are obliged to case of technicians is allowed
foreigner should ask for up to a maximum of 15% of
request it to the Panamanian another type of migratory foreign personnel working in
Consulates located around permit. Employees should
the world. They must provide a company.
obtain a work permit after
details of their time of arrival, their arrival to Panama which Employment contract
place and length of their stay must be renewed annually.
in Panama. 49. In general, all foreign
nationals working in the
46. To obtain a work permit, it is
43. Expatriates who do not need Republic of Panama, are
necessary to make a formal
a visa or have a tourist visa request duly signed by the required to have an
are allowed to stay for ninety employment contract, which
employer, and provide a
days in the Panamanian should establish the terms
confirmation of the employer
territory, but if more time is existence to the labor office. and conditions set down by
required, they can ask for an the employer during the time
extension that will be given 47. The formal request must be of employee´s assignment in
for sixty more days. filed by the employee and the Panama.
Foreigners are not allowed to employer, who must submit
It is important to mention
work in Panama without a some legal documents to the
that the work permit is only
work permit and previous labor authorities.
registration at the Social processed when submitting
some documents to the Labor

12 Human Resources Services


authorities, including the
employment contract.

Importing personal
possessions
50. The expatriate is allowed to
import personal possessions
up to US$1,250 (custom
value); of this amount
US$500 is duty-free, and the
remaining US$750 is taxed
with an import duty of 20%
plus the value added tax,
which is 7%.

51. Foreigners coming to Panama


with an executive migratory
permit, for being working
with an international
Company, are allowed to
import their personal
possessions without any tax,
as long as they have the
referred permit and
temporary residence.

The foreigner should request,


by written, the exemption for
importing the goods before
the Panama Custom Agency,
which will provide a form
regarding the referred
import; the form should be
kept as it will be required
when re-exporting the
household back to the home
country at the end of the
assignment.

Importing your car


52. If the expatriate imports
his/her car for personal use it
will be necessary to do a
payment in concept of
custom duties.

International Assignment Taxation Folio 13


Step 4:
What to do when you arrive in the
Republic of Panama
Residence permits by the law for each type of 57. The registration for tax
migratory permit. The purposes is important not
53. When arriving to Panama National Migratory Services only to satisfy a legal
with or without a visa Office will issue, if applies, a requirement but also due to
(depending on the country Permanent Definitive the fact that upon tax
you are coming from), Resolution with the registration, you will receive a
foreigners are allowed to corresponding ID document. registration number (8-NT);
obtain a residence permit in which should be used in any
the country for one or two Tax registration communication with the
years, (depending on the type 56. If you are employed by a Panamanian tax authorities
of the permit they request), Panamanian employer it is and to obtain a tax solvency,
as long as they complete all possible that you might need that is going to be needed for
requirements determined by to file an annual income tax the renewal of the migratory
the Migratory Agency. return. The tax authorities permit.
54. Once the foreigner enters in require that you obtain a tax
ID number (8-NT) in order to
the country, it is necessary to
be registered in the Ministry
register at the Foreigners
Section of the National of Economy and Finance
database. The procedure to
Migratory Service Office,
obtain this number is the
where a unique identification
number will be granted and following: you must complete
a Tax ID form and present it
used for migratory affairs as
with complimentary
an identification number.
documentation such as
55. After the expiration of the complete passport, power of
migratory permit, it will be attorney (if applicable)
required to renew it for the immigration identification,
same consecutive period up social security slip, salary
to a maximum of six years, certificate and taxes withheld
through a previous request by the employer, certificate of
made by the expatriate, that marriage (if applicable),
should include water, telephone, electricity
complimentary bill or any other similar that
documentation established indicates the requestor
address.

14 Human Resources Services


Step 5:
What to do at the end of the year
Tax return submissions Paying your tax liability Advance tax payments

58. If an employee receives 62. The position outlined below, 66. After you, as an independent
assume that the tax liability contractor, submit your first
income in salary and
has not been completely tax return, you will be
representation expenses
derived from only one source, performed through the required to make advanced
payroll withholding. tax payments respect the
he/she might have the option
following fiscal year. The
to file an annual income tax 63. Generally, taxes are payable
return or not. amount of these payments
in advance. depends on the amount
59. A foreign individual will be calculated as tax liability on
64. However, for the year in
required to submit a tax which you arrive, the full tax the previous fiscal year. The
return in the following cases: advanced tax payments
liability is due on the day of
if he/she stays in Panama for should be made in three
submission of your first tax
more than 183 days in a tax return, since it would not different installments after
year; if he/she receives the original payment on
exist any tax liability on
benefits in kind as part of its March 31st. These
Panama before; therefore no
remuneration; or if it is tax advances were paid. installements are on June
employed by a foreign firm 30th, September 30th, and
that has a permanent 65. If taxes are generated, December 31st. Overdue
establishment in the Republic payment must be made by payments will trigger
of Panama. March 31st at the latest, in surcharges and interests. If
order to avoid suercharges you are an employee
60. The tax returns must be filed and interests. These receiving salary, no tax
by March 15th of the payments must be submitted advance payment is required.
following year in which the to a specific Bank with a
income was generated. 67. You should be aware that
special slip indicating that tax
Spouses can file either joint payment was made. If these payments are treated as
or independent returns. advances of your tax liability
taxpayers request for an
corresponding to the next
Applying for an extension extension, this only applies to
the filing of the return not to fiscal year, which means that
61. The deadlines for filing the if the tax return for the first
the tax payment. Overdue
income tax return may be year is filed on March of the
payments may trigger
extended to April 15th, if the penalties from a $100.00 per second year, and are
taxpayers ask for the calculated tax advanced
return and interests
extension before March 15th. payments; then a first
approximately of 11%
annually. payment must be done before
Mach 31st, corresponding to

International Assignment Taxation Folio 15


the incomes received in the There are also interests for However, where there are no
first year; and on June 30th, late payment of your tax tax arrears, the taxpayer can
September 30th and liability; these are apply for a refund of overpaid
December 31st, advanced approximately of 1% of tax though a process
payments must be done for unpaid tax for each month of determined by the tax
the estimated tax, generated late payment. legislation.
from the incomes received on
the current second year. Tax overpayment
69. An overpaid tax can be
Penalties and Interests compensated by the tax
68. The tax authorities may levy a administration against other
penalty for late submission of owed taxes, if any; and the
your tax return. In practice it balance can be credited
is determined between against future tax liability.
US$100 and US$500.

16 Human Resources Services


Step 6:
What to do when you leave
the Republic of Panama
Informing the financial Filing your tax return Exporting your personal
authority 71. You may submit your final possessions
tax return before your 72. Exportation is free of duty in
70. Both, the Tax Administration
departure from the Republic Panama. Therefore, taxes will
as well as the Migration
of Panama. Otherwise your not arise due to the
Authority need to be advised
tax return should be prepared exportation of personal
within 30 days after the
and submitted within the possessions or vehicles.
completion of your
normal filing period. As you
assignment in Panama and
will not be present in the
that you have left the
Republic of Panama, it is
Republic of Panama
recommended that you
permanently as an employee.
designate a tax advisor with a
This will release you from any
general power of attorney to
obligation to pay further tax
act on your behalf for this
advances and penalties.
purpose. Your final income
tax return shall be submitted
within the next thirty (30)
days after your last working
day in Panama.

International Assignment Taxation Folio 17


Step 7:
Other matters requiring consideration
Health and social security 74. Health insurance is employee is required to pay
contributions administered by the 9.75% of their salary and the
government and individuals employer a rate of 12.25% on
73. Health and social security can use public hospitals, the gross income of every
contributions are required for which are specially designed employee. Social security
every employee working for public health insurance, contributions include the
within Panama. Social which covers health and following benefits: health,
security contributions do not medical care. sickness, maternity and
have a cap. pension or retirement.
75. For both health and social
security contributions, the

18 Human Resources Services


Appendix A:
Tax rates for individuals
Tax rates

If taxable income is Taxes payable will be


Up to B/.11,000.00 0%
More than B/.11,000.00 up to B/.50,000.00 15% rate on amounts exceeding B/.11,000.00 up to
B/.50,000.00.
More than B/.50,000.00 B/.5,850.00 for the first B/.50,000.00 and an
applicable rate of 25% on amounts exceeding
B/.50,000.00

Special tax rates for representation expenses


If taxable income is Taxes payable will be
Up to B/.25,000.00 10%
More than B/.25,000.00 Will pay B/.2,500.00 for the first B/.25,000.00 and a
rate of 15% over exceeding amounts.

International Assignment Taxation Folio 19


Appendix B:
Individual tax calculation
Tax computation
Assumptions:
1. Tax Resident married

2. Exchange rate of the balboa at January 1, 2007: US$1 = B/. 1.0361

Salary 80,000
Less—Deductions:
 Interest on mortgage (15,000)

 Charitable contributions (500)


(15,500)
Subtotal 64,500
Less—Personal exemptions:
 Joint return (800)
(800)
Taxable income 63,700
Tax thereon:
 On first 50,000 5,850

 On remaining 13,700 at 25% 3,425


Tax payable 9,275

20 Human Resources Services


Appendix C:
Principal IAS contacts
Contacts
Francisco A. Barrios G. Ericka Elías
Tel: (507) 206-9217 Tel: (507) 206-1313
Fax: (507) 206-9292 Fax: (507) 206-9292
Email: francisco.barrios@pa.pwc.com Email: ericka.e.elias@pa.pwc.com
Hassim Patel Bhana Hamnia De Sedas
Tel: (507) 206-9200 Tel: (507) 206-1304
Fax: (507) 206-9292 Fax: (507) 206-9292
Email: hassim.patel.bhana@pa.pwc.com Email: hamnia.de.sedas@pa.pwc.com

Offices

Panama City
PricewaterhouseCoopers
Avenida Samuel Lewis y
Calle 55 E
Urbanización Obarrio, Panamá
Panama

International Assignment Taxation Folio 21


© 2015 PricewaterhouseCoopers LLP. All rights reserved. PwC refers to the United States member firm, and may sometimes refer to the PwC
network. Each member firm is a separate legal entity. Please see www.pwc.com/structure for further details.

“PricewaterhouseCoopers” and “PwC” may also refer to one or more member firms of the network of member firms of PricewaterhouseCoopers
International Limited (PwCIL), each of which is a separate legal entity.

PricewaterhouseCoopers does not act as agent of PwCIL or any other member firm nor can it control the exercise of another member firm’s
professional judgement or bind another firm or PwCIL in any way.

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