UCB SA - BNP Paribas Fortis

more detailed proposal for amendments to the EU Savings Directing which included a number of
suggested changes. The European Parliament expressed its opinion on the proposal on 24 April 2009
and the Council adopted unanimous conclusions on 9 June 2009 relating to the proposal. If any of those
proposed changes are made in relation to the EU Savings Directive, they may amend or broaden the
scope of the requirements described above.
The rate of the Source Tax was 15 per cent. until 30 June 2008 and has increased to 20 per cent. on 1
July 2008. The rate of the Source Tax will increase to 35 per cent. on 1 July 2011.
Bondholders who are individuals or certain other persons and receive interest on the Bonds should note
that additional amounts which may become due as described in Condition 7 “Taxation”, will not be due
in respect of the Source Tax.
Individuals not resident in Belgium
A Belgian paying agent will withhold a tax at source at the current rate of 20 per cent. on the interest
payments made to an individual, beneficial owner of the interest payments and resident in another EU
Member State or resident in one of the Associated and Dependant Territories.
The Source Tax is levied in addition to the Belgian withholding tax which has been withheld.
The Source Tax is levied pro rata to the period of holding of the Bonds by the beneficial owner of the
interest payments.
No Source Tax will be applied if the investor provides the Belgian paying agent with a certificate drawn
up in his name by the competent authority of his state of residence for tax purposes. The certificate must
at least indicate: (i) name, address and tax or other identification number or, in the absence of the latter,
the date and place of birth of the beneficial owner; (ii) name and address of the paying agent; and (iii)
the account number of the beneficial owner, or where there is none, the identification of the security.
Individuals resident in Belgium
An individual resident in Belgium will be subject to the provisions of the Savings Directive, if he
receives interest payments from a paying agent (within the meaning of the Savings Directive)
established in another EU Member State, Switzerland, Liechtenstein, Andorra, Monaco, San Marino,
the Netherlands Antilles, Aruba, Guernsey, Jersey, the Isle of Man, Montserrat, the British Virgin
Islands, Anguilla, the Cayman Islands or the Turks and Caicos Islands.
If the interest received by an individual resident in Belgium has been subject to a Source Tax, such
Source Tax does not liberate the Belgian individual from declaring the interest income in the personal
income tax declaration. The Source Tax will be credited against the personal income tax. If the Source
Tax withheld exceeds the personal income tax due, the excessive amount will be reimbursed, provided it
reaches a minimum of Euro 2.5.
2. LUXEMBOURG TAXATION
The following discussion is a summary of the Luxembourg tax consequences to potential purchasers or
holders of Bonds, based on current law and practice in Luxembourg. This discussion is for general
information purposes only and does not purport to be a comprehensive description of all possible tax
consequences that may be relevant. Potential purchasers of Bonds should consult their own professional
advisers as to the consequences of making an investment in, holding or disposing of the Bonds and the
receipt of any amount in connection with the Bonds.
A11250830/2.25/23 Oct 2009 129