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

Under a tax amendment introduced in July 2009, donation of debt securities between corporate entities became
exempt from gift tax. The relevant rules are, nonetheless, unclear yet as to whether such exemption also
applies where any of the parties is a foreign corporation.
8.4.3 Expected changes as of 1 January 2010
8.4.3.1 Corporate Income Taxation
Tax Residents
The most important change in corporate taxation from 2010 will be the abolishing of the 4% solidarity surtax
and the simultaneous increasing of the general corporate income tax rate from 16% to 19%.
Additionally, both the inter company financing and the stock exchange investment related special tax base
deductions will be abolished.
Withholding Tax
From 2010, 30% withholding tax will be introduced on interest paid to residents of countries with which Hungary
has not concluded double taxation treaties.
8.4.3.2 Personal Income Taxation
As of 2010, the rate of the health care contribution payable on the income category described under Section
8.4.2.2.1 /d) Underlying payments / yields during holding the instrument (non-stock exchange)) will increase
from 11 percent to 27 percent.
In addition, the 4% solidarity surtax will be abolished and the aggregate taxable basis will be subject to 17
percent personal income tax up to the first HUF 5 million (approximately EUR 19,000) part thereof and 32
percent above that. First time next year, as a new feature of the Hungarian personal income taxation, the aggregate
taxable basis will include not only the individuals gross income but also the 27 percent health care
contribution.
8.5 Luxembourg
The following is a general description of certain Luxembourg tax considerations relating to the Securities. It
does not purport to be a complete analysis of all tax considerations relating to the Securities, whether in Luxembourg
or elsewhere. Prospective purchasers of the Securities should consult their own tax advisers as to
which countries' tax laws could be relevant to acquiring, holding and disposing of the Securities and receiving
payments of interest, principal and/or other amounts under the Securities and the consequences of such actions
under the tax laws of Luxembourg. This summary is based upon the law as in effect on the date of this Prospectus.
The information contained within this section is limited to taxation issues, and prospective investors
should not apply any information set out below to other areas, including (but not limited to) the legality of
transactions involving the Securities.
8.5.1 Withholding Tax
Save for what is stated below, under Luxembourg tax law, there is no withholding tax for Luxembourg resident
and non-resident holders of the Securities on payments of interest (including accrued but unpaid interest)
on the Securities. There also is no Luxembourg withholding tax payable on payments made upon repayment
of the principal or upon redemption of the Securities.
On June 3, 2003, the EU Council of Economic and Finance Ministers adopted a directive on the taxation of
interest income from savings (Directive 2003/48/EC) (the EU Savings Directive). Under the EU Saving
Directive, each EC member state which has adopted the Euro as its lawful currency (Participating Member
State) generally must provide to the tax authorities of another Participating Member State details of interest
payments or similar income paid by a Paying Agent within its jurisdiction to a Residual Entity (as defined in
the next paragraph and footnote 8 below) or to or for an individual (the Actual Owner) resident in the latter
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