AEG 21604 G Manual de usuario descargar pdf (Pagina 227)

216

TAXATION

Taxation in Luxembourg

The following information is of a general nature only and is based on the Issuer’s understanding of cer-

tain aspects of the laws and practice in force in Luxembourg as of the date of this Prospectus. It does not

purport to be a comprehensive description of all of the tax considerations that might be relevant to an

investment decision. It is included herein solely for preliminary information purposes. It is not intended to

be, nor should it be construed to be, legal or tax advice. It is a description of the essential material Lux-

embourg tax consequences with respect to the Notes and may not include tax considerations that arise

from rules of general application or that are generally assumed to be known to Noteholders. This sum-

mary is based on the laws in force in Luxembourg on the date of this Prospectus and is subject to any

change in law that may take effect after such date. Prospective Noteholders should consult their profes-

sional advisors with respect to particular circumstances, the effects of state, local or foreign laws to

which they may be subject and as to their tax position.

Please be aware that the residence concept used under the respective headings applies for Luxembourg

income tax assessment purposes only. Any reference in the present section to a tax, duty, levy impost or

other charge or withholding of a similar nature refers to Luxembourg tax law and/or concepts only. Also,

please note that a reference to Luxembourg income tax encompasses corporate income tax (impôt sur le

revenu des collectivités), municipal business tax (impôt commercial communal), a solidarity surcharge

(contribution au fonds pour l’emploi), as well as personal income tax (impôt sur le revenu) generally.

Noteholders may further be subject to net worth tax (impôt sur la fortune) as well as other duties, levies

or taxes. Corporate income tax, municipal business tax as well as the solidarity surcharge invariably

apply to most corporate taxpayers resident of Luxembourg for tax purposes. Individual taxpayers are

generally subject to personal income tax and the solidarity surcharge. Under certain circumstances,

where an individual taxpayer acts in the course of the management of a professional or business under-

taking, municipal business tax may apply as well.

Taxation of the Issuer

Income tax

The Issuer is a fully-taxable Luxembourg company. The net taxable profit of the Issuer is subject to Lux-

embourg corporate income tax and municipal business tax.

The taxable profit as determined for corporate income tax purposes is applicable, with minor adjustments,

for municipal business tax purposes. Corporate income tax is levied at an effective maximum rate of

21.84 % in 2010 (inclusive of the 4 % surcharge for the employment fund). Municipal business tax is

levied at a variable rate according to the municipality in which the company is located (6.75 % in Luxem-

bourg-city). The maximum aggregate corporate income tax and municipal business tax rate consequently

amounts to 28.59 % for companies located in Luxembourg-city in 2010.

The taxable profits of the Issuer is computed by application of the rules of the amended Luxembourg in-

come tax law of 4 December 1967 (loi concernant l'impôt sur le revenu), as commented and currently

applied by the Luxembourg tax authorities. The taxable profit as determined for corporate income tax

purposes is applicable, with minor adjustments, for municipal business tax purposes.

Net Worth Tax

As a rule, the Issuer is subject to Luxembourg net worth tax at the rate of 0.5 % applied on net assets as

determined for net worth tax purposes. Net worth is referred to as the unitary value (valeur unitaire), as

determined at 1 January of each year. The unitary value is in principle calculated as the difference be-

tween (i) assets estimated at their fair market value (valeur estimée de réalisation), and (ii) liabilities vis-

à-vis third parties.

1 2 ... 222 223 224 225 226 227 228 229 230 231 232 ... 650 651

Comentarios a estos manuales

Sin comentarios

AEG 21604 G Manual de usuario Pagina 227

Comentarios a estos manuales

Relacionado con productos y manuales para Placas AEG 21604 G