Prospectus - Notowania

and is an employee of the Company. Additional details are applied to this request.
60% of such dividends are subject to tax (partial income method,
Teileinkünfteverfahren) based on the progressive rate applicable to the individual
shareholder (tax rate up to 45%) plus 5.5% solidarity tax thereon (resulting in a
maximum total tax rate of 47.5% in case of maximum personal rate of 45%) plus
church taxes, if applicable. The expenses economically correlated to said dividend
income may be deducted exclusively within the limit of 60%. Additionally, the
standard deduction for investment income is not allowed.
Shares Owned as Company Assets
If the shares are owned as company assets, taxation depends on whether the
shareholder is a joint-stock company, a sole proprietorship or a commercial
partnership (Mitunternehmerschaft).
The taxes withheld by the German payment agent and paid to the German tax
authorities are credited to offset the shareholder’s liabilities for income taxes (of the
company) (and of the liabilities for church taxes, if applicable) within the scope of the
formal assessment procedure or reimbursed to the extent to which there was a
payment exceeding what was due; the same scheme is applied to the solidarity tax.
The special fixed tax rate is not applied.
Shareholders incorporated in the form of joint-stock companies
With certain exceptions for companies operating in the finance and insurance industry,
in general 95% of dividends received by joint-stock companies residing in Germany
(or entities whose registered office or place of actual management and control is in
Germany) are exempt from company income taxes and from the solidarity tax. 5% of
dividends received is considered non-deductible company cost and, therefore, it is
subjected to income taxes on companies at the rate of 15% plus 5.5% of solidarity tax
thereon (for a total rate of 15.825%). However, all actual expenses directly related to
the dividends are deductible in principle. No minimum holding threshold or minimum
duration of possession is applied. However, the entire amount of any dividend
remaining after the deduction of expenses related to the dividends is subject to trade
taxes, unless the company owns 10% of more of the share capital of the Company at
the start of the pertinent tax period. In this case only 5% of the dividends is subject to
trade taxes.
Sole proprietorships
If the shares are owned as a company asset by a sole proprietorship, 60% of dividends
is subject to income taxes. Only 60% of company expenses economically correlated to
such dividends are tax deductible. If the shares are owned as assets of a business
enterprise or of a company, the dividends are totally subject to trade taxes, unless the
taxpayer owns 10% or more the share capital of the Company at the start of the
pertinent tax period. In this case, the net amount of the dividends, i.e. after the
deduction of company expenses directly related to the dividends, is exempt from trade
taxes. Trade taxes are generally credited for the shareholder’s personal tax liabilities in
accordance with the standard tax credit method.
- 421 -