Prospectus-Final (clean) - Malta Financial Services Authority

Gift and Inheritence TaxesDutch gift or inheritance taxes will not be levied on the occasion of the transfer of a Note by way of giftby, or on the death of, a holder of a Note, unless:(i) the holder of a Note is, or is deemed to be, resident in The Netherlands for the purpose of therelevant provisions; or(ii) the transfer is construed as an inheritance or gift made by, or on behalf of, a person who, at thetime of the gift or death, is or is deemed to be resident in The Netherlands for the purpose ofthe relevant provisions.Value added TaxThe issuance or transfer of a Note, and payments of interest and principal under a Note, will not besubject to value added tax in The Netherlands.Other Taxes and DutiesThe subscription, issue, placement, allotment, delivery or transfer of a Note will not be subject toregistration tax, stamp duty or any other similar tax or duty payable in The Netherlands.ResidenceA holder of a Note will not be, or deemed to be, resident in The Netherlands for tax purposes and,subject to the assumptions and exceptions set out above, will not otherwise be subject to Dutchtaxation, by reason only of acquiring, holding or disposing of a Note or the execution, performance,delivery and/or enforcement of a Note.EU Savings Tax DirectiveIn accordance with EC Council Directive 2003/48/EC on the taxation of savings income, TheNetherlands will provide to the tax authorities of another EU member state (and certain non-EUcountries and associated territories specified in said directive) details of payments of interest or othersimilar income paid by a person within The Netherlands to, or collected by such a person for, anindividual resident in such other state.3. LuxembourgNon-ResidentsUnder the existing laws of Luxembourg and except as provided for by the Luxembourg laws of21 June 2005 implementing the EU Savings Tax Directive (as defined below), there is no withholdingtax on the payment of interest on, or reimbursement of principal of, the Notes made to non-residentsof Luxembourg.Under the Luxembourg laws of 21 June 2005 implementing the EU Savings Tax Directive and as aresult of ratification by Luxembourg of certain related Accords with the relevant dependent andassociated territories (as defined under the EU Savings Tax Directive), payments of interest or similarincome made or ascribed by a paying agent established in Luxembourg to or for the immediate benefitof an individual holder of a Note or certain residual entities, who, as a result of an identificationprocedure implemented by the paying agent, are identified as residents or are deemed to be residentsof an EU Member State other than Luxembourg or certain of those dependent or associated territoriesreferred to under "EU Savings Tax Directive" below, will be subject to a withholding tax unless therelevant beneficiary has adequately instructed the relevant paying agent to provide details of therelevant payments of interest or similar income to the fiscal authorities of his/her country of residenceor deemed residence or, in the case of an individual holder of a Note, has provided a tax exemptioncertificate from his/her fiscal authority in the format required by law to the relevant paying agent.Where withholding tax is applied, it will be levied at a rate of 35% since 1 July 2011.202