080305_JPM Series Fix and Win ... - Börse Stuttgart

per cent. The Sparer-Freibetrag and the standard deduction will be converted into a unitary flat sum (Sparer-
Pauschbetrag) for the overall investment income in the amount of 801 Euro (1,602 Euro for married couples
filing their tax return jointly). The deduction of actually accrued expenses will not be possible any more.
Non-Tax residents
Persons who are not tax resident in Germany, are in general exempt from the German Kapitalertragsteuerabzug
plus solidarity surcharge. In the case of over-the-counter-transactions (payment or credit upon presentation of
Notes or Coupons at the office of a German credit or financial services institution or at a German branch of a
foreign institution or at a German securities trading firm or a German securities trading bank), with the
exception of transactions entered into by foreign credit or financial services institutions, the 25 per cent.
Kapitalertragsteuerabzug plus solidarity surcharge, in total 26.375 per cent. applies. Under certain circumstances
a refund might be available.
If according to German tax law the interest income received from the Notes kept or administered by a German
credit or financial services institution (or by a German branch of a foreign institution) or by a German securities
trading firm or a German securities trading bank is effectively connected with a German trade or business of a
non-resident, the taxation corresponds to the taxation set out in the paragraph "Tax residents" above.
Luxembourg Taxation
The statements herein regarding taxation in Luxembourg are based on the laws in force in the Grand Duchy of
Luxembourg as of the date of this Document and are subject to any changes in law. The following summary
does not purport to be a comprehensive description of all the tax considerations which may be relevant to a
decision to purchase, own or dispose of the Notes. Each prospective holder or beneficial owner of the Notes
should consult its tax advisor as to the Luxembourg tax consequences of the ownership and disposition of the
Notes.
The following is a summary of certain Luxembourg tax consequences for Holders of Instruments. The summary
is based on legislation as at the date of this document and is intended to provide general information only. The
tax treatment of each Holder partly depends on the Holder's specific situation. Each Holder should consult a tax
adviser as to the tax consequences relating to their particular circumstances resulting from holding
Instruments.
Non-Residents
A Holder of Instruments (in the following sections regarding United States taxation, "Notes" and "Instruments"
refers to securities issued under the Programme generally) will not become resident, or deemed to be resident, in
Luxembourg by reason only of the holding of the Instruments or the execution, performance and/or delivery of
the Instruments.
Under the existing laws of Luxembourg and except as provided for by the Luxembourg law of 21 June 2005
implementing the EU Savings Tax Directive, there is no withholding tax on the payment of interest on, or
reimbursement of principal of, the Instruments made to non-residents of Luxembourg through a paying agent
established in Luxembourg.
Under the Luxembourg law of 21 June 2005 implementing the EU Savings Tax Directive and as a result of
ratification by Luxembourg of certain related Accords with the relevant dependent and associated territories,
payments of interest or similar income made or ascribed by a paying agent established in Luxembourg to or for
the immediate benefit of an individual or certain residual entities as defined by the law, who, as a result of an
identification procedure implemented by the paying agent, are identified as residents or are deemed to be
residents of an EU Member State other than Luxembourg or certain of those dependent or associated territories
referred to under the EU Savings Tax Directive, will be subject to a withholding tax unless the relevant
beneficiary has adequately instructed the relevant paying agent to provide details of the relevant payments of
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