AEG 21604 G Bedienungsanleitung PDF herunterladen (Seite 229)

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Other taxes

There is no Luxembourg value added tax payable in respect of payments in consideration for the issuance

of the Notes, or in respect of the payment of interest or principal under the Notes, or the transfer of the

Notes. Luxembourg value added tax may, however, be payable in respect of fees charged for certain ser-

vices rendered to the Issuer, if for Luxembourg value added tax purposes such services are rendered or

are deemed to be rendered in Luxembourg and an exemption from Luxembourg value added tax does not

apply with respect to such services.

The issue of shares against contributions in cash as well as other amendments to the articles of incorpora-

tion are currently subject to a EUR 75 fixed registration duty. The issuance of the Notes is not subject to a

Luxembourg registration tax or stamp duty, unless recorded in a Luxembourg notarial deed or otherwise

registered in Luxembourg (which is generally not mandatory).

Taxation of the Noteholders

Luxembourg tax residency of the Noteholders

A Noteholder will not become resident, nor be deemed to be resident, in Luxembourg by reason only of

the holding of the Notes, or the execution, performance, delivery and/or enforcement of the Notes.

Withholding Tax

Resident Noteholders

Under the Luxembourg law dated 23 December 2005, a 10 % withholding tax is levied as of 1 January

2006 on interest payments (or similar income) made by a Luxembourg paying agent to or for the immedi-

ate benefit of a Luxembourg resident individual. This withholding tax also applies on accrued interest

received upon disposal, redemption or repurchase of the Notes. Such withholding tax will be in full dis-

charge of income tax if the beneficial owner is an individual acting in the course of the management of

his/her private wealth.

Further, a Luxembourg resident individual who acts in the course of the management of his/her private

wealth and who is the beneficial owner of an interest payment made by a paying agent established outside

Luxembourg in a Member State of the European Union or of the European Economic Area or in a juris-

diction having concluded an agreement with Luxembourg in connection with the European Council Di-

rective 2003/48/EC on taxation of savings income (the “EU Savings Directive”), may also opt for a final

10 % levy. In such case, the 10 % levy is calculated on the same amounts as for the payments made by

Luxembourg resident paying agents. The option for the 10% levy must cover all interest payments made

by the paying agent to the Luxembourg resident beneficial owner during the entire civil year.

Non-resident Noteholders

Under the Luxembourg tax law currently in effect and subject to the application of the Luxembourg laws

dated 21 June 2005 implementing the EU Savings Directive (the “Luxembourg Laws”) and several

agreements concluded between Luxembourg and certain dependant territories of the European Union,

there is no withholding tax on payments of interests (including accrued but unpaid interest) made to a

Luxembourg non-resident Noteholder, repayment of the principal, or redemption or exchange of the

Notes.

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AEG 21604 G Bedienungsanleitung Seite 229