Prospectus - Notowania

dividends distributed by the aforesaid companies if such dividends are entitled to the
exemption in accordance with the EC Directive on the taxation of parent – subsidiary
companies (Directive 90/435/CEE of the Council of July 23, 1990, as amended).
Inheritance Tax and Donation Tax
The transfer of the shares to a different person for donation or inheritance is generally
subject to German inheritance and donation taxes only if:
(i) the deceased, donor, heir, beneficiary or other assign has the residence or place
of habitual abode in Germany or has its principal place of business or registered
office in Germany at the time of the transfer, or is a German citizen who spent
no longer than five consecutive years abroad without maintaining residency in
Germany, or
(ii) the shares are owned by the deceased or by the donor as parts of company assets
in relation to which a permanent company site exists in Germany or in relation
to which a permanent representative has been appointed in Germany.
The few treaties against double taxation for inheritance and donation taxes in force in
Germany generally provide that German inheritance or donation taxes may be
assessed solely in the cases set out in point (i) above and, with certain limitations, in
point (ii) above.
Special rules apply to certain German citizens who have neither their residence nor
habitual abode in Germany and to former German citizens.
Other Taxes
No transfer tax, value added tax, stamp tax or other similar tax is applied on the
purchase, on the sale or on other transfers of the shares. However, in certain
circumstances the Company may opt for payment of the value added taxes on
transactions that would otherwise be exempt from said tax. Currently, no capital tax
(Vermögensteuer) is applied in Germany.
Starting from the 2009 tax period, a shareholder subject to church taxes may decide,
through a written request to the payment agent, to ask that the church taxes due in
relation to his capital investments be withheld at the source. Additional details are
applied to this request. The shareholder’s liability relating to the church taxes on his
own investment income is considered liquidated through the withholding tax. The
church taxes thereby withheld may not be deducted as special personal expenses
within the scope of the formal assessment procedure. As compensation, the church
taxes withheld on investment income are reduced by 25% with respect to what is
ordinarily due for such church taxes on said investment income.
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