AEG 21604 G Bedienungsanleitung PDF herunterladen (Seite 233)

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Luxembourg resident companies

A Luxembourg resident company (société de capitaux) must include interest and gains realized on the

sale or disposal of the Notes in its taxable income for Luxembourg income tax assessment purposes. Tax-

able gains are determined as being the difference between the sale, repurchase or redemption price (in-

cluding accrued but unpaid interest) and the lower of the cost or book value of the Notes sold or re-

deemed.

Luxembourg residents benefiting from a special tax regime

Luxembourg residents who benefit from a special tax regime, such as, for example, (i) holding companies

subject to the amended law of 31 July 1929, (ii) undertakings for collective investment subject to the

amended laws of 20 December 2002, (iii) specialised investment funds subject to the law dated 13 Febru-

ary 2007 or (iv) family wealth management companies subject to the law dated 11 May 2007, are exempt

from income tax in Luxembourg and thus income derived from the Notes, as well as gains realised

thereon, are not subject to Luxembourg income taxes.

Taxation of Luxembourg non-residents

A non-resident who has neither a permanent establishment nor a permanent representative in Luxembourg

to which the Notes are attributable is not liable to any Luxembourg income tax, whether he receives pay-

ments of principal or interest (including accrued but unpaid interest) or realizes capital gains upon re-

demption, repurchase, sale or exchange of any Notes.

A Luxembourg non-resident who has a permanent establishment or a permanent representative in Lux-

embourg to which the Notes are attributable has to include any interest, as well as any capital gain real-

ized on the sale or disposal of the Notes, in his/her taxable income for Luxembourg income tax assess-

ment purposes.

Net Wealth Tax

A Luxembourg resident or a non-resident who has a permanent establishment or a permanent representa-

tive in Luxembourg to which the Notes are attributable is subject to Luxembourg net wealth tax on such

Notes, except if the Noteholder is (i) a resident or non-resident individual taxpayer, (ii) a holding com-

pany subject to the amended law of 31 July 1929, (iii) an undertaking for collective investment subject to

the amended law of 20 December 2002, (iv) a securitisation company governed by the law of 22 March

2004 on securitisation, (v) a company governed by the law of 15 June 2004 on venture capital vehicles,

(vi) a specialized investment fund subject to the law of 13 February 2007 or (vii) a family wealth man-

agement company subject to the law of 11 May 2007.

Other Taxes

Registration taxes and stamp duties

There is no Luxembourg registration tax, stamp duty or any other similar tax or duty payable in Luxem-

bourg by the Noteholders as a consequence of the issuance of the Notes, nor will any of these taxes be

payable as a consequence of a subsequent transfer, redemption or repurchase of the Notes.

Value added tax

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.

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