Vorarlberger Landes- und Hypothekenbank Aktiengesellschaft

espectively.
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If the Notes are not kept in a custodial account with a Disbursing Agent and interest or proceeds from the
disposition of Coupons are paid or credited by a Disbursing Agent to a non-resident of the Federal
Republic of Germany (other than a non-German bank or financial services institution) upon delivery of the
Coupons, such payments will also be subject to withholding tax to the extent and at a rate as explained
above at "Notes held by tax residents as private assets".
Inheritance and Gift Tax
No inheritance or gift taxes with respect to any Note will generally arise under the laws of the Federal
Republic of Germany, if, in the case of inheritance tax, neither the decedent nor the beneficiary, or, in the
case of gift tax, neither the donor nor the donee, is a resident of the Federal Republic of Germany and
such Note is not attributable to a German trade or business for which a permanent establishment is
maintained, or a permanent representative has been appointed, in the Federal Republic of Germany.
Exceptions from this rule apply to certain German citizens who previously maintained a residence in the
Federal Republic of Germany.
Other Taxes
No stamp, issue, registration or similar taxes or duties will be payable in the Federal Republic of Germany
in connection with the issuance, delivery or execution of the Notes. Currently, net assets tax
(Vermögensteuer) is not levied in the Federal Republic of Germany.
Republic of Austria
Under Austrian tax law, individuals are subject to income tax generally at progressive tax rates between
0% and 50%. Corporate entities are subject to a corporate income tax at a rate of 25%. Interest income in
respect of the Notes that is received by individual Austrian residents, as described below, is generally
subject to a 25% flat-rate taxation.
(i) Investors subject to unlimited tax liability ("residents")
The following two captions (a. Interest payments and b. Capital gains) described the general Austrian tax
law consequences regarding the Notes, some specific tax law consequences regarding certain types of
Notes are described under caption "c. Some specific rules regarding various types of Notes" below.
a. Interest payments
Interest payments in respect of Notes made by an Austrian paying agent (kuponauszahlende Stelle) or by
the Issuer directly to residents, in accordance with the terms and conditions of the Notes, will generally be
subject to withholding tax on investment income (Kapitalertragsteuer) at a rate of 25%. Pursuant to
Austrian tax law, individuals with a domicile or habitual abode in the Republic of Austria and corporate
entities with their legal seat or effective place of management in the Republic of Austria are regarded as
residents.
Insofar as the Notes have been publicly offered, the withholding tax on investment income levied on
interest payments in respect of Notes to individuals (and corporate entities, insofar as the interest
payments qualify as income from investment of capital and not as income from a business) is final
(Endbesteuerung – "Final Taxation"). Such interest payments are not assessed and taxed together with
other income.
However, there is an option to have such interest payments in respect of Notes assessed and taxed
together with other income, if such assessment and taxation more favourable than Final Taxation. In that
case, the withholding tax on investment income would be treated as a prepayment on income tax and the
withholding tax on investment income is credited against the tax liability for the respective year.
Interest payments in respect of Notes made by a non-domestic agent or person making the payments to
individuals (and to corporate entities insofar the interest payments qualify as income from investment of
capital and not as business income of a trade or business) are taxed separately from any other income at
a special rate of 25%. Such taxation is deemed to be equivalent to Final Taxation.
However, there is also an option to have such interest payments in respect of Notes assessed and taxed
with any other income if more favourable than taxation at the special rate.