Dit prospectus is gemaakt voor de uitgifte van dit product en ... - Iex

TAXATIONGeneralThe following summary describes the principal Dutch, Belgian, Luxembourg and U.S. tax consequences ofthe acquisition, holding, redemption and disposal of Notes, which term, for the purpose of this summary,includes Coupons, Receipts and Talons. This summary does not purport to be a comprehensive description ofall Dutch, Belgian, Luxembourg and U.S. tax considerations that may be relevant to a decision to acquire, tohold, and to dispose of the Notes. Each prospective Noteholder should consult a professional adviser withrespect to the tax consequences of an investment in the Notes. The discussion of certain Dutch, Belgian,Luxembourg and U.S. taxes set forth below is included for general information purposes only.This summary is based on the Dutch, Belgian, Luxembourg and U.S. tax legislation, published case law,treaties, rules, regulations and similar documentation, in force as of the date of this Offering Circular, withoutprejudice to any amendments introduced at a later date and implemented with retroactive effect.This summary does not address the Dutch tax consequences for:(i)(ii)(iii)Noteholders holding a substantial interest (aanmerkelijk belang) in the Issuer. Generally speaking, aNoteholder holds a substantial interest in the Issuer, if such holder, alone or, where such holder is anindividual, together with his or her partner (statutory defined term) or certain other related persons,directly or indirectly, holds (a) an interest of 5 per cent. or more of the total issued capital of the Issueror of 5 per cent. or more of the issued capital of a certain class of shares of the Issuer, (b) rights toacquire, directly or indirectly, such interest or (c) certain profit sharing rights in the Issuer.Pension funds or other entities that are exempt from Dutch corporate income tax.Investment institutions as defined in Dutch tax law (“fiscale beleggingsinstellingen” or “vrijgesteldebeleggingsinstellingen”).1. The Netherlands1.1 Withholding TaxAll payments in respect of the Notes can be made without withholding or deduction for or on accountof any taxes, duties or charges of any nature imposed whatsoever that are or may be withheld orassessed by the Netherlands Tax Authorities or any political subdivision thereof or therein.1.2 Corporate Income Tax and Individual Income TaxA corporate Noteholder, that derives income from a Note or that realises a gain on a disposal, deemeddisposal, exchange or redemption of the Note, will not be subject to any Netherlands taxes on suchincome or capital gains, unless:(i)(ii)the Noteholder is, or is deemed to be a resident of the Netherlands; orthe Noteholder has (an interest in) an enterprise that is, in whole or in part, carried on througha permanent establishment or a permanent representative in the Netherlands, to whichenterprise or part of an enterprise the Note is attributable.An individual Noteholder, who derives or is deemed to derive income from a Note or who realizes again on the disposal, deemed disposal, exchange or redemption of the Note, will not be subject to any313