COREALCREDIT BANK AG

Holders who are individuals should note that the Issuer will not pay additional amounts under
§ 7(c) of the Terms and Conditions of the Notes in respect of any withholding tax imposed as a
result of the EU Savings Tax Directive.
Investors should note that the European Commission adopted an amending proposal to the EU
Savings Tax Directive, which, among other changes, seeks to extend the application of the EU
Savings Tax Directive to (i) payments channelled through certain intermediate structures (whether
or not established in a member state) for the ultimate benefit of an EU resident individual, and (ii) a
wider range of income similar to savings income. Further developments in this respect should be
monitored on a continuing basis, since no certainty exists over whether and when the proposed
amendments to the EU Savings Tax Directive will be implemented. Investors who are in any doubt
as to their position should consult their professional advisors.
Luxembourg
Non-residents
Under the existing laws of Luxembourg and except as provided for by the Luxembourg laws of 21
June 2005 implementing the EU Savings Tax Directive (as defined above), there is no withholding
tax on interest (paid or accrued) on, or reimbursement of principal of, the Notes made to nonresidents
of Luxembourg.
Under the Luxembourg laws of 21 June 2005 implementing the EU Savings Tax Directive and as a
result of ratification by Luxembourg of certain related Accords with the relevant dependent and
associated territories of the European Union, payments of interest or similar income made or
ascribed (attribué) by a paying agent established in Luxembourg to or for the immediate benefit of
an individual or certain residual entities within the meaning of Article 4.2 of the EU Savings Tax
Directive (i.e., entities which are not legal persons (the Finnish and Swedish companies listed in
Article 4.5 of the EU Savings Tax Directive are not considered as legal persons for this purpose),
whose profits are not taxed under the general arrangements for the business taxation and that are
not, and have not opted to be treated as, UCITS recognised in accordance with the Council
Directive 85/611/EEC as replaced by the Council Directive 2009/65/EC or similar collective
investment funds located in Jersey, Guernsey, the Isle of Man, the Turks and Caicos Islands, the
Cayman Islands, Monserrat or the British Virgin Islands), will be subject to a withholding tax,
unless the relevant beneficiary has adequately instructed the relevant paying agent to provide
details of the relevant payments of interest or similar income to the fiscal authorities of his/her
country of residence or deemed residence or has provided a tax certificate from his/her fiscal
authority in the format required by law to the relevant paying agent. Where withholding tax is
applied, it will be levied at a rate of currently 35 per cent.
When used in the preceding paragraph "interest" and "paying agent" have the meaning given
thereto in the Luxembourg laws of 21 June 2005 (or the relevant Accords). "Interest" will include
accrued or capitalised interest at the sale, repayment or redemption of the Notes. "Paying agent"
is defined broadly for this purpose and in the context of the Notes means any economic operator
established in Luxembourg who pays interest on the Notes to or ascribes the payment of such
interest to or for the immediate benefit of the beneficial owner, whether the operator is, or acts on
behalf of, the Issuer or is instructed by the beneficial owner to collect such payment of interest.
Payments of interest or similar income under the Notes to Clearstream Banking AG, Clearstream
Banking, société anonyme and Euroclear Bank SA/NV and payments by or on behalf of
Clearstream Banking, société anonyme to financial intermediaries will not give rise to a withholding
tax under Luxembourg laws.
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