AEG 21604 G Manual de usuario descargar pdf (Pagina 239)

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Notes held by non-residents

Interest and capital gains are not subject to German taxation in the case of non-residents, i.e. persons hav-

ing neither their residence nor their habitual abode nor legal domicile nor place of effective management

in the Federal Republic of Germany, unless the Notes form part of the business assets of a permanent

establishment maintained in the Federal Republic of Germany. Interest may, however, also be subject to

German income tax if it otherwise constitutes income taxable in Germany, such as income from the let-

ting and leasing of certain German property or income from certain capital investments directly or indi-

rectly secured by German real estate.

Non-residents of the Federal Republic of Germany are in general exempt from German withholding tax

on interest and capital gains and from solidarity surcharge thereon. However, if the interest or capital gain

is subject to German taxation as set forth in the preceding paragraph and the Notes are held in a custodial

account with a Disbursing Agent, withholding tax will be levied as explained above under “Taxation -

Taxation in the Federal republic of Germany - Income Tax – Notes held by tax residents in Germany

where the Notes do not form part of the business assets” or under “– Notes held by tax residents in Ger-

many where the Notes form part of the business assets”, respectively.

Inheritance and Gift Tax

No inheritance or gift tax with respect to any Note will generally arise under the law of the Federal Re-

public of Germany, if, in the case of inheritance tax, neither the decedent nor the beneficiary, or, in the

case of gift tax, neither the donor nor the donee, is a resident of the Federal Republic of Germany and

such Note is not attributable to a German trade or business for which a permanent establishment is main-

tained, or a permanent representative has been appointed, in the Federal Republic of Germany. Excep-

tions from this rule apply to certain German citizens who previously maintained a residence in the Federal

Republic of Germany.

Other Taxes

No stamp, issue, registration or similar taxes or duties will be payable in the Federal Republic of Ger-

many in connection with the issuance, delivery or execution of the Notes. Currently, wealth tax (Ver-

mögenssteuer) is not levied in the Federal Republic of Germany.

EU Savings Tax Directive

Under the EU Council Directive 2003/48/EC dated June 3, 2003 on the taxation of savings income in the

form of interest payments (“EU Savings Directive”) each EU Member State shall require paying agents

(within the meaning of such directive) established within its territory to provide to the competent author-

ity of this state details of the payment of interest made to any individual resident in another EU Member

State as the beneficial owner of the interest. The competent authority of the EU Member State of the pay-

ing agent is then required to communicate this information to the competent authority of the EU Member

State of which the beneficial owner of the interest is a resident.

For a transitional period, Austria and Luxembourg may instead opt to withhold tax from interest pay-

ments within the meaning of the EU Savings Directive at a rate of 20 % from 1 July 2008, and of 35 %

from 1 July 2011. Belgium has decided to opt for the withholding tax only until 31 December 2009 and to

apply the information procedure described above as from 2010.

In Germany, provisions for the implementation of the EU Savings Directive have been enacted by legisla-

tive regulations of the Federal Government (so called Zinsinformationsverordnung) dated 26 January

2004. These provisions apply since 1 July 2005.

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