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

Interest derived by Belgian corporate investors on the Notes and capital gains realised on the Noteswill be subject to Belgian corporate income tax at the ordinary rate of 33.99 per cent. Capital losses onthe Notes are in principle tax deductible.Payments of interest (as defined in the section “Individuals resident in Belgium”) on the Notes madethrough a Belgian establishment of a financial intermediary will in principle be subject to a 15 percent. withholding tax in Belgium (calculated on the interest received after deduction of any non-Belgian withholding taxes). However, interest payments made to a Belgian corporation may qualifyfor an exemption from withholding tax if a certificate is delivered (articles 108 and 117, § 12 RoyalDecree implementing the Belgian Income tax Code). The Belgian withholding tax that has been leviedis creditable and refundable in accordance with the applicable legal provisions.Other Belgian legal entitiesLegal entities that are Belgian residents for tax purposes, i.e. that are subject to Belgian tax on legalentities (“Rechtspersonenbelasting” / “impôt des personnes morales”) are subject to the following taxtreatment in Belgium with respect to the Notes.Payments of interest (as defined in the section “Individuals resident in Belgium”) on the Notes madethrough a Belgian establishment of a financial intermediary will in principle be subject to a 15 percent. withholding tax in Belgium and no further tax on legal entities will be due on the interest.However, if the interest is paid outside Belgium, i.e. without the intervention of a financialintermediary in Belgium, the legal entity itself is liable for the payment of the Belgian 15 per cent.withholding tax.Capital gains realised on the sale of the Notes are in principle tax exempt, unless the capital gainqualifies as interest (as defined in the section “Individuals resident in Belgium”). Capital losses onthe Notes are in principle not tax deductible.Organisation for Financing PensionsBelgian pension fund entities that have the form of an Organisation for Financing Pensions (“OFP”)are subject to Belgian Corporate Income Tax (“Vennootschapsbelasting” / “Impôt des sociétés”). OFPare subject to the following tax treatment in Belgium with respect to the Notes.Interest derived on the Notes and capital gains realised on the Notes will not be subject to BelgianCorporate Income Tax in the hands of OFP. Any Belgian withholding tax that has been levied iscreditable and refundable in accordance with the applicable legal provisions.Belgian non-residentsThe interest income on the Notes paid to a Belgian non-resident outside Belgium, i.e. without theintervention of a Belgian establishment of a financial intermediary, is not subject to Belgianwithholding tax.Interest income on the Notes paid through a Belgian intermediary will in principle be subject to a 15per cent. Belgian withholding tax, unless the Note holder is resident in a country with which Belgiumhas concluded a double taxation agreement and delivers the requested affidavit.An exemption from Belgian withholding tax is available under Belgian domestic provisions in case ofpayment of interest on the Notes through an intermediary established in Belgium, provided that suchintermediary qualifies as a recognised credit institution, stock exchange company or clearing or316