Prospectus - Notowania

Commercial Partnerships
If the shareholder is a partnership, the income taxes on natural persons or the income
taxes on legal persons shall be assessed solely at the individual partner level. If the
shareholder is a joint-stock company fiscally residing in Germany, 95% of dividends
will generally be tax exempt (see the previous Paragraph on joint-stock companies). If
the shareholder is a natural person, 60% of dividends will be subject to income taxes
on natural persons, including the solidarity tax and church taxes, if applicable (see the
previous Paragraph on sole proprietorships).
In principle, the total amount of the dividends is subject to trade taxes at the
partnership level if the shares are owned as commercial or company assets, regardless
of whether the shareholders are natural persons or corporations. If the partnership
owned at least 10% of the share capital of the Company at the start of the pertinent tax
period, only 5% of the dividends is subject to trade taxes to the extent to which the
shareholders are joint-stock companies; the net amount of the remaining part, i.e. after
the deduction of company expenses directly associated to the dividends, is entirely
exempt from trade taxes. For shareholders who are natural persons, the trade taxes
paid by the company are credited against the personal tax liabilities for income taxes
of each shareholder in accordance with the standard tax credit method.
Taxation of Capital Gains Deriving from the Transfer of the Shares
Shares acquired before January 1, 2009 and owned as private assets
The capital gains deriving from the transfer of shares owned as private assets by a
natural person who resides in Germany are generally subject to income taxes
according to the tax rate applicable to said person, plus 5.5% of solidarity tax thereon
and church taxes, if applicable, provided that (i) the transfer takes place within one
year from the date of acquisition of the shares (“Short Term Sale”), or (ii) the natural
person or, in the case of a gratuitous transfer, any predecessor in title of the natural
person has, at any time during the five years immediately preceding the transfer,
owned directly or indirectly an interest in the Company of 1% or more (“Substantial
Holding”). In case of transfer of shares from a Substantial Holding after December
31, 2008, 60% of the capital gain is subject to taxes and 60% of the expenses
economically related to said transfer can be deducted from the taxable amount. In case
of transfer of shares from a Short Term Sale after December 31, 2008, 50% of the
capital gain is subject to taxes and 50% of the expenses economically related to said
transfer can be deducted from the taxable amount.
Capital gains deriving from Short Term Sales are not taxed if, together with any other
capital gain deriving from private transactions within the calendar year, they amount
to €600. Capital losses deriving from Short Term Sales of shares may be brought to
offset the capital gains deriving from private transactions during the same calendar
year or, in the absence of such capital losses, in the previous year or in subsequent
years, provided that certain conditions are met. Alternatively, the capital losses
deriving from Short Term Sales may be brought to offset the income from investment
of capital received between 2009 and 2013.
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