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ule apply to certain German expatriates.
Other Taxes
No stamp, issue, registration or similar taxes or duties will be payable in Germany in connection with the
issuance, delivery or execution of the Notes. Currently, net assets tax is not levied in Germany.
European Directive on the Taxation of Savings Income
Germany has implemented the EU Savings Tax Directive into national legislation by means of an Interest
Information Regulation (Zinsinformationsverordnung, ZIV) in 2004. Starting on 1 July 2005, Germany has
therefore begun to communicate all payments of interest on the Notes and similar income to the beneficial owners
Member State of residence if the instruments have been kept in a custodial account with a Disbursing Agent.
EU Savings Tax Directive
Under the EU Savings Tax Directive each EU Member State must require paying agents (within the meaning of
the EU Savings Tax Directive) established within its territory to provide to the competent authority of this state
details of the payment of interest made to any individual resident in another EU Member State as the beneficial
owner of the interest. The competent authority of the EU Member State of the paying agent is then required to
communicate this information to the competent authority of the EU Member State of which the beneficial owner
of the interest is a resident.
For a transitional period, Austria, Belgium and Luxembourg may opt instead to withhold tax from interest
payments within the meaning of the EU Savings Tax Directive at a rate of 20 per cent. since 1 July 2008, and of
35 per cent. from 1 July 2011.
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