SEC Form 20-F - Deutsche Bank Annual Report 2012

Deutsche Bank
Annual Report 2010 on Form 20-F
Item 10: Additional Information 127
With some exceptions, corporations or individuals residing in Germany are required to report to the Bundesbank
any payment received from, or made to or for the account of, a nonresident corporation or individual that
exceeds € 12,500 (or the equivalent in a foreign currency). This reporting requirement is for statistical purposes.
Subject to the above-mentioned exceptions, there are currently no German laws, decrees or regulations that
would prevent the transfer of capital or remittance of dividends or other payments to our shareholders who are
not residents or citizens of Germany.
There are also no restrictions under German law or our Articles of Association concerning the right of nonresident
or foreign shareholders to hold our shares or to exercise any applicable voting rights. Where the investment
reaches or exceeds certain thresholds, certain reporting obligations apply and the investment may become
subject to review by the BaFin and other competent authorities. See “Item 10: Additional Information – Memorandum
and Articles of Association – Notification Requirements” in our Annual Report on Form 20-F for the
year ended December 31, 2008.
Taxation
The following is a summary of the material German and United States federal income tax consequences of the
ownership and disposition of shares for a resident of the United States for purposes of the income tax convention
between the United States and Germany (the “Treaty”) who is fully eligible for benefits under the Treaty. A U.S.
resident will generally be entitled to Treaty benefits if it is:
— the beneficial owner of shares (and of the dividends paid with respect to the shares);
— an individual resident of the United States, a U.S. corporation, or a partnership, estate or trust to the extent
its income is subject to taxation in the United States in its hands or in the hands of its partners or beneficiaries;
— not also a resident of Germany for German tax purposes; and
— not subject to “anti-treaty shopping” articles under German domestic law or the Treaty that apply in limited
circumstances.
The Treaty benefits discussed below generally are not available to shareholders who hold shares in connection
with the conduct of business through a permanent establishment in Germany. The summary does not discuss
the treatment of those shareholders.
The summary does not purport to be a comprehensive description of all of the tax considerations that may be
relevant to any particular shareholder, including tax considerations that arise from rules of general application
or that are generally assumed to be known by shareholders. In particular, the summary deals only with shareholders
that will hold shares as capital assets and does not address the tax treatment of shareholders that are
subject to special rules, such as fiduciaries of pension, profit-sharing or other employee benefit plans, banks,
insurance companies, dealers in securities or currencies, persons that hold shares as a position in a straddle,
conversion transaction, synthetic security or other integrated financial transaction, persons that elect mark-tomarket
treatment, persons that own, directly or indirectly, ten percent or more of our voting stock, persons that
hold shares through a partnership and persons whose “functional currency” is not the U.S. dollar. The summary
is based on German and U.S. laws, treaties and regulatory interpretations, including in the United States current
and proposed U.S. Treasury regulations as of the date hereof, all of which are subject to change (possibly with
retroactive effect).