COMMERZBANK AKTIENGESELLSCHAFT

Other taxes
The purchase, sale or other disposal of Notes does not give rise to capital transfer tax, value added
tax, stamp duties or similar taxes or charges in Germany. However, under certain circumstances
entrepreneurs may choose liability to value added tax with regard to the sales of Notes which would
otherwise be tax exempt. Net wealth tax (Vermögensteuer) is, at present, not levied in Germany.
Switzerland
The following section gives a summary of the taxation of Fixed Rate Notes, Zero-Coupon-Notes and
Floating Rate Notes (jointly referred to as "Standard-Notes") as well as structured Notes. The tax
treatment of structured Notes (comprising, without limitation, notes in respect of which the interest
rate, interest amount or redemption amount is to be determined by reference to shares, share baskets,
indices, index baskets, currencies and currency baskets (jointly referred to as "Structured Notes")),
depends on the specific features of the respective notes.
Income Taxation
Notes and Structured Notes held as private assets
Standard-Notes
Holders of Standard-Notes who are individuals resident in Switzerland for tax purposes holding
Standard-Notes as private assets and receiving payments of interest on Standard-Notes (no matter
whether the Standard-Notes are classified as bearing a "predominant-one-time-interest-payment" or
not, as explained below) are required to include such payments in their income tax return and will be
taxable on any net taxable income (including the payments of interest on the Standard-Notes) for the
relevant tax period.
If such Holder of Standard-Notes sells or otherwise disposes of Standard-Notes during the taxation
year, he or she realises either a tax-free capital gain or a tax-neutral capital loss, provided that such
Standard-Notes are not classified as Standard-Notes with a "predominant one-time-interest-payment"
(Obligation mit überwiegender Einmalverzinsung). Standard-Notes are classified as being
predominant-one-time-interest-bearing if the yield-to-maturity predominately derives from one-timeinterest-payments
such as an original issue discount or a repayment premium rather than from
periodic interest payments. In that case, the amount received upon sale or redemption less the issue
price (if the Standard-Notes were purchased at their issuance) or the purchase price (if the Standard-
Notes were purchased thereafter) will be classified as a taxable interest payment (as opposed to a taxfree
capital gain). Losses realised on the sale of Standard-Notes with a "predominant one-timeinterest-payment"
may be offset against gains realised within the same tax period on the sale of any
notes with a "predominant one-time-interest-payment" (plus the periodic income thereon). Repayment
of capital is not taxable.
Structured Notes
Structured Notes are composed of a derivative financial instrument and a bond. If the bond part of the
Structured Note can not been recorded separate from the derivative financial instrument, the
Structured Note will be classified as a non-transparent derivative financial instrument and the entire
return on the Structured Note over the initial investment will be classified as a taxable interest
payment. Non-transparent derivative financial instruments will usually be classified as notes with a
"predominant one-time-interest-payment" and be taxed in accordance with the principles set forth
above relative to Standard-Notes with a "predominant one-time-interest-payment".
If the bond part of Structured Notes can be set and if further the predominant interest yield of the
Structured Notes does derive from a one-time-interest-payment, then any value increase on the bond
part from purchase to sale or redemption will be taxable pursuant to the so-called "modified method of
spread taxation" (Modifizierte Differenzbesteuerung). Any other payment or return will be classified as
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