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

to dispose of the Notes. In some cases, different rules can be applicable. This summary does notdescribe the tax consequences for a holder of Notes that are redeemable in exchange for, orconvertible into shares, of the exercise, settlement or redemption of such Notes. Furthermore, the taxrules can be amended in the future, possibly implemented with retroactive effect, and theinterpretation of the tax rules may change.Each prospective holder of Notes should consult a professional adviser with respect to the taxconsequences of an investment in the Notes, taking into account the influence of each regional, localor national law.2.1 Withholding Tax and Income TaxIndividuals resident in BelgiumIndividuals who are Belgium-residents for tax purposes, i.e. individuals subject to the Belgianindividual income tax (“Personenbelasting” / “Impôt des personnes physiques”) and who hold theNotes as a private investment, are subject to the following tax treatment in Belgium with respect to theNotes. Other tax rules apply to Belgium-resident individuals holding the Notes not as a privateinvestment but in the framework of their professional activity or when their transactions with respectto the Notes fall outside the scope of the normal management of their own private estate.Under Belgian tax law, “interest” income includes: (i) periodic interest income, (ii) any amount paidby the Issuer in excess of the issue price (whether or not on the maturity date), and (iii) if the Notesqualify as “fixed income securities” (within the meaning of article 2, §1, 8° Belgian Income TaxCode), in the case of a realisation of the Notes between two interest payment dates, the interestaccrued during the detention period. In general, notes are qualified as fixed income security if there isa causal link between the amount of interest income and the detention period of the notes, on the basisof which it is possible to calculate the amount of pro rata interest income at the moment of the sale ofthe notes during their lifetime.Payments of interest on the Notes made through a Belgian establishment of a financial intermediarywill in principle be subject to a 15 per cent. withholding tax in Belgium (calculated on the interestreceived after deduction of any non-Belgian withholding taxes). The Belgian withholding taxconstitutes the final income tax for Belgium-resident individuals. This means that they do not have todeclare the interest obtained on the Notes in their personal income tax return, provided Belgianwithholding tax was levied on these interest payments.However, if the interest is paid outside Belgium, i.e. without the intervention of a financialintermediary established in Belgium, the interest received on the Notes (after deduction of any non-Belgian withholding tax) must be declared in the personal income tax return of the holder of Notesand will be taxed at a flat rate of 15 per cent. plus communal surcharges.Capital gains realised upon the sale of the Notes are in principle tax exempt, unless the capital gainsare realised outside the scope of the management of one’s private estate or unless the capital gainsqualify as interest (as defined above). Capital losses are in principle not tax deductible.Belgium-resident corporationsCorporations that are Belgium-residents for tax purposes, i.e. corporations subject to BelgianCorporate Income Tax (“Vennootschapsbelasting” / “Impôt des sociétés”) are subject to the followingtax treatment in Belgium with respect to the Notes.315