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

their own professional advisers as to the effects of state, local or foreign laws, including Luxembourgtax law, to which they may be subject.3.1 Withholding Tax – Non-resident holders of NotesUnder Luxembourg general tax laws currently in force and subject to the laws of 21 June 2005 (the“Laws”) mentioned below, there is no withholding tax on payments of principal, premium or interestmade to non-resident holders of Notes, nor on accrued but unpaid interest in respect of the Notes, noris any Luxembourg withholding tax payable upon redemption or repurchase of the Notes held by nonresidentholders of Notes.Under the Laws implementing the EC Council Directive 2003/48/EC of 3 June 2003 on the taxationof savings income in the form of interest payments (herein referred to as the Savings Directive) andseveral agreements concluded between Luxembourg and certain dependent or associated territories ofthe European Union (the “Territories”), payments of interest or other similar income made orascribed by a paying agent established in Luxembourg (within the meaning of the Savings Directive)to (or under certain circumstances, for the immediate benefit of) an individual beneficial owner inanother EC Member State or in one of the Territories will be subject to a withholding tax, unless therelevant recipient has adequately instructed the relevant paying agent to provide details of the relevantpayments of interest or similar income to the fiscal authorities of his or her country of residence orestablishment, or, in the case of an individual beneficial owner, has provided a tax certificate issuedby the fiscal authorities of his or her country of residence in the required format to the relevant payingagent. The same treatment will apply to payments of interest and other similar income made to certain“residual entities” within the meaning of Article 4.2 of the Savings Directive established in an ECMember State or in one of the Territories (i.e. entities which are not legal persons (the Finnish andSwedish companies listed in Article 4.5 of the Savings Directive are not considered as legal personsfor this purpose), whose profits are not taxed under the general arrangements for business taxation,that are not UCITS recognised in accordance with the Council Directive 85/611/EEC or similarcollective investment funds located in Jersey, Guernsey, the Isle of Man, the Turks and CaicosIslands, the Cayman Islands, Montserrat or the British Virgin Islands and have not opted to be treatedas UCITS recognised in accordance with the Council Directive 85/611/EEC).Where withholding tax is applied, it will be levied at a rate of 20 per cent., increasing to 35 per cent.as from 1 July 2011. The withholding tax system will only apply during a transitional period, theending of which depends on the conclusion of certain agreements relating to information exchangewith certain third countries. Responsibility for the withholding of the tax will be assumed by theLuxembourg paying agent.3.2 Withholding Tax – Resident holders of NotesUnder Luxembourg general tax laws currently in force and subject to the law of 23 December 2005 asamended by the law of 17 July 2008 mentioned below, there is no withholding tax on payments ofprincipal, premium or interest made to Luxembourg resident holders of Notes, nor on accrued butunpaid interest in respect of Notes, nor is any Luxembourg withholding tax payable upon redemptionor repurchase of Notes held by Luxembourg resident holders of Notes.Payments of interest or similar income made or ascribed by a paying agent established in Luxembourg(defined in the same way as in the Savings Directive) to or for the immediate benefit of an individualbeneficial owner who is a resident of Luxembourg or to certain residual entities that secure interestpayments on behalf of such individuals (unless such entities have opted either to be treated as UCITSrecognised in accordance with the Council Directive 85/611/EEC or for the exchange of informationregime) will be subject to a withholding tax of 10 per cent. Responsibility for the withholding of thetax will be assumed by the Luxembourg paying agent.319