JPMorgan - KASE

Tax on Income and Capital Gains
A holder of a note will not be subject to Dutch taxation on (deemed) income or capital gains in
respect of that note, provided that such holder of a note:
(i)
(ii)
is neither a tax resident nor deemed to be a tax resident of the Netherlands, nor, if such
holder is an individual, has elected to be taxed as a resident of the Netherlands;
does not have an enterprise, or an interest in an enterprise, which is, in whole or in part,
carried on through a permanent establishment or permanent representative in the
Netherlands to which or to whom such (deemed) income or capital gains are attributable or
are deemed attributable;
(iii) is not entitled to a share in the profits of or has an interest in an enterprise effectively
managed in the Netherlands other than by way of the holding of securities or through an
employment contract, to which enterprise the (deemed) income or capital gains are
attributable;
(iv) in the case such holder is an individual, does not perform activities in the Netherlands with
respect to the notes that exceed normal asset management;
(v)
in the case such holder is an individual, does not have, and certain persons related or
deemed related to that holder do not have, directly or indirectly, a substantial interest, as
defined in the Netherlands Income Tax Act 2001 (Wet inkomstenbelasting 2001), in the
issuer, or in any company that legally or in fact, directly or indirectly, has the disposition of
any part of the proceeds of the notes; and
(vi) in the case such holder is not an individual, does not have, directly or indirectly, a substantial
interest or a deemed substantial interest, as defined in the Netherlands Income Tax Act 2001
(Wet inkomstenbelasting 2001), in the Company, or, in the event that the holder does have
such interest, it forms part of the assets of an enterprise.
If a holder of a Note is not a resident or a deemed resident in the Netherlands, but is a resident
in another country the following may apply. If a double taxation convention is in effect between
the Netherlands and the country in which such holder of a note is resident, such holder may,
depending on the terms of and subject to compliance with the procedures for claiming benefits
under such double taxation convention, be eligible for a full or partial exemption from
Netherlands taxes (if any) on (deemed) income or capital gains in respect of a note provided such
holder is entitled to the benefits of that treaty.
Gift, Estate, or Inheritance Tax
No gift, estate or inheritance tax will arise in the Netherlands on a transfer of a note by way of
gift by, or on the death of a holder of a note who is neither a resident, nor a deemed resident of
the Netherlands, provided that:
(i)
(ii)
such transfer is not construed as an inheritance, a bequest or a gift by or on behalf of a
person who, at the time of the gift or his death, is or was a resident or a deemed resident of
the Netherlands;
such holder of a note does not have an enterprise, or an interest in an enterprise, which is
carried on through a permanent establishment or permanent representative in the
Netherlands and to which enterprise the note is or was attributable; and
(iii) such holder of a note is not entitled to a share in the profits of an enterprise effectively
managed in the Netherlands other than by way of the holding of securities or through an
employment contract, to which enterprise the note is or was attributable; and
such holder of a note does not die within 180 days after the date of a gift of a Note made while
that holder was a resident or a deemed resident of the Netherlands.
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