COREALCREDIT BANK AG

Inheritance tax / gift tax
The transfer of Notes to another person by way of gift or inheritance is subject to German gift or
inheritance tax, respectively, if
(i) the deceased, the donor, the heir, the donee or any other acquirer had his residence or
habitual abode in Germany at the time of the transfer of property, or has not permanently
stayed in a foreign country for more than five years as German citizen without having a
residence in Germany, or is subject to an employment contract with a legal entity under
public law as German citizen (or a relative of German citizenship leaving in the same
household), or
(ii) the deceased, the donor, the heir, the donee or any other acquirer is a corporation,
partnership or formation of a company (Vermögensmasse) having its place of management
or office in the Federal Republic of Germany, or
(iii) the Notes are part of a domestic property (Inlandsvermögen) within the meaning of section
121 German Valuation Tax Act (Bewertungsgesetz), or
(iv) the deceased or the donor, being German citizens, are subject to extended limited tax
liability according to the German Foreign Tax Act after moving away from the Federal
Republic of Germany.
Investors are urged to consult with their tax advisor to determine the particular inheritance or gift
tax consequences in light of their particular circumstances.
Other taxes
The purchase, sale or other disposal of Notes does not give rise to capital transfer tax, value
added tax, stamp duties or similar taxes or charges in Germany. However, under certain
circumstances entrepreneurs may choose liability to value added tax with regard to the sales of
Notes which would otherwise be tax exempt. Net wealth tax (Vermögensteuer) is, at present, not
levied in Germany.
EU Savings Tax Directive
Under the EU Council Directive 2003/48/EC dated 3 June 2003 on the taxation of savings income
in the form of interest payments (the "EU Savings Tax Directive"), which is applicable as from
1 July 2005, each EU member state must require paying agents (within the meaning of such
directive) established within its territory to provide to the competent authority of this state details of
the payment of interest made to any individual resident in another EU member state as the
beneficial owner of the interest. The competent authority of the EU member state of the paying
agent (within the meaning of the EU Savings Tax Directive) is then required to communicate this
information to the competent authority of the EU member state of which the beneficial owner of the
interest is a resident.
For a transitional period, Austria and Luxembourg may opt instead to withhold tax from interest
payments within the meaning of the EU Savings Tax Directive at a rate of currently 35 per cent.
In conformity with the prerequisites for the application of the EU Savings Tax Directive, a number
of non-EU countries and territories, including Switzerland, have agreed to apply measures
equivalent to those contained in such directive (a withholding system in the case of Switzerland).
In Germany, provisions for implementing the EU Savings Tax Directive have been enacted by
legislative regulations of the Federal Government. These provisions apply as from 1 July 2005.
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