I This document constitutes the base prospectus of ... - Volksbank AG

8.4.2.2.2 Non Residents
Non resident individuals are subject to income tax on their Hungarian source income under the same rules as
residents. The source of income in the case of interest payment is generally the state of the payer. If the interest
payment is made via a domestic PE, branch or commercial representative, the source of income will be
Hungary. If the claim which represents the source of the interest belongs to the PE of the entitled individuals,
the source of the interest will also be Hungary.
8.4.2.3 Inheritance and Gift Tax
8.4.2.3.1 Inheritance Tax
Under the Hungarian laws securities situated in Hungary inherited by either Hungarians or non Hungarian
citizens may be subject to inheritance tax. Should the bonds be situated abroad (we believe that there are
strong arguments that securities kept at foreign bank accounts or physically located abroad should fall within
this category) individuals are liable to pay inheritance tax as long as the other country does not impose such a
tax on the respective securities. The taxable base is generally the net value of the inheritance. The applicable
rate of the inheritance tax depends on the relationship between the disposer and the beneficiary. There are
three groups of beneficiaries:
1. Children / spouse / parents,
2. Other close relatives, and
3. Others
In case of the first group (children / spouse / parents) the applicable rates are 11 percent, 15 percent, 21 percent
according to a progressive scale depending on the value of the bond inherited. If the taxable amount is up
to HUF 18 million (approx. EUR 67,000), the first category has to applied; the second category has to be applied
when the taxable amount is between HUF 18 and 35 million (approx. EUR 130,000) for the excess part,
and the inheritance tax has to be levied at 21 percent if the taxable amount exceeds HUF 35 million (again for
the excess part).
If other close relatives inherit the applicable rates are 15 percent, 21 percent and 30 percent respectively.
In case of the third group (others) the applicable rates are 21 percent, 30 percent and 40 percent according to
the above mentioned categories.
Since 1 January 2009, in the case of beneficiaries listed in the first group, HUF 20 million (approx EUR
74,000) from the heritage is exempt from inheritance tax. In the calculation of such beneficial portion, the
value of the inherited real-estate has to be first taken into account.
8.4.2.3.2 Gift Tax
Under the effective Hungarian law gift tax applies to the donation of bond transferred in Hungary. The taxable
base is the net value of the gift. The applicable rates depend on the relationship between the donor and the
recipient. The groups are the same as determined for inheritance tax. The applicable rates are as follows.
For the first group (children / spouse / parents) the applicable rates are 11 percent, 18 percent, 21 percent depending
on the value of the security.
If another close relative is the recipient, the applicable rates are 15 percent, 21 percent and 30 percent accordingly.
In case of the third group (others) the applicable rates are 21 percent, 30 percent and 40 percent respectively.
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