DIE ERSTE österreichische Spar-Casse ... - ERSTE Stiftung

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Under the double taxation treaty between Austria and the Czech Republic, interest paid from Austria to a Czech tax resident is taxable in the Czech Republic. However, the Austrian paying agent may under certain conditions deduct withholding tax from interest payments on the Notes in Austria if the Council Directive 2003/48/EC of 3 June 2003 on taxation of savings income in the form of interest payments (the "EU Savings Directive") is applicable (see "Austria" above). Interest paid on the Notes to a Czech tax resident from foreign sources is subject to income tax in the Czech Republic. Individual investors An individual investor must include the interest received in his overall personal income tax base, which is taxable at a flat rate of 15%. If a withholding tax is deducted on the interest in Austria under the EU Savings Directive, the individual Czech tax resident may declare the tax deducted in Austria on his Czech income tax return and claim a credit against his Czech tax liability due on the income in respect of which the deduction was made. If the deduction is greater than the tax liability, the resident may claim the amount of the surplus from the Czech tax authority. Corporations A corporation must include the interest received in its general corporate income tax base, which is taxable at a flat rate of 19%. Inheritance and gift tax If acquiring the Notes as a gift or as an inheritance, resident (and under certain circumstances also non-resident) individuals and corporations are liable to pay the Czech gift tax or inheritance tax. The Czech gift tax rate ranges from 1% to 40% and the Czech inheritance tax rate ranges from 0.5% to 20%. Applicable tax rates depend on the value of the assets transferred and on the relationship between the deceased/the donor on the one hand and the heir/the donee on the other hand. A tax exemption may be applied in specific cases, such as succession by direct relatives and spouses. Other taxes No other taxes are levied in the Czech Republic on the acquisition, sale or other disposal of the Notes. Non-residents Tax non-residents are subject to tax only on their Czech source income. Income derived by a permanent establishment located in the Czech Republic is deemed to be Czech source income. Each individual or corporation that receives income subject to Czech tax is obliged to file an application for registration with the tax authority unless it is accidental or just a one-time tax liability. Income may be exempt from taxation or the tax liability may be reduced under the terms of a relevant double taxation treaty. Interest Interest income paid by a Czech paying agent to a non-resident may be treated as Czech source income. In this case the Czech paying agent withholds a 15% withholding tax from the Page 80
interest paid (with the exception of interest paid to a Czech permanent establishment). The withholding tax rate may be reduced by an applicable double taxation treaty. If the interest is considered as income of a permanent establishment, the withholding tax does not apply and the individual or corporation having the permanent establishment has to pay tax on the interest income in the same way as tax residents (see the section on residents above). Under the EU Interest Royalty Directive, the interest paid by the Czech company to related company located in EU countries or in the Switzerland, Denmark or Iceland may be exempt from withholding tax if certain additional conditions are met.Capital gains Income from the sale of the Notes payable by a Czech tax resident or by a permanent establishment of a Czech tax non-resident located in the Czech Republic to a non-resident shall be treated as Czech source income taxable in the Czech Republic. The income may be exempt from taxation under an applicable double taxation treaty. If no double taxation treaty applies, the following Czech taxation should be taken into account: Individual investors Capital gains from the sale of the Notes are exempt from Czech personal income tax if an individual has held the Notes as a non-business asset for an uninterrupted period of more than six months. This time limit only applies to investment securities where a shareholding comprises a maximum of 5%. Otherwise, the individual must hold the Notes for an uninterrupted period of more than five years for the personal income tax exemption to be applicable. Either way, the exemption only applies if the Notes have not been included in the individual’s business assets at any point in time prior to their sale. If capital gains from the sale of the Notes held by individuals as a non-business asset are not tax-exempt, they are subject to personal income tax at a flat rate of 15%, the tax base being calculated as the income from the sale of the Notes reduced by the purchase price of the Notes and charges related to their acquisition. A loss from the sale of the Notes may be offset against gains from the sale of the Notes or other securities in the same fiscal period. In the case of individuals holding the Notes as a business asset the capital gain from the sale of the Notes is included in their general income tax base and taxed at a flat rate of 15%. A loss from the sale of the Notes may be offset against overall taxable income (other than employment income) in the current fiscal period and the following five fiscal periods. Corporations Capital gains from the sale of the Notes held by corporations are included in their general income tax base and taxed at a flat rate of 19% in 2011. A loss from the sale of the Notes may be offset against profits in the current fiscal period and the following five fiscal periods. Purchase of the Notes from a non-EEA resident A Czech resident who purchases the Notes from a resident from outside the European Economic Area is obliged to withhold and pay a tax security advance at a rate of 1% of the purchase price for the Notes to the Czech tax authorities unless the respective double taxation treaty provides tax exemption of the capital gain in the Czech Republic. If no double taxation treaty is applicable, the seller should file a Czech corporate/personal income tax return, in which the withheld tax security advance is deducted from the final tax liability assessed at regular tax rates. If no tax return is filed, the tax security advance withheld will be treated as the final tax. Page 81
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DIE ERSTE österreichische Spar-Cas
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In this Prospectus, unless otherwis
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SELLING RESTRICTIONS ..............
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DOCUMENTS INCORPORATED BY REFERENCE
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SUMMARY OF THE PROGRAMME This summa
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Credit Risk Credit risk is the risk
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Business of ERSTE Foundation DIE ER
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Risk Factors arising from Erste Gro
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RISK FACTORS Prospective investors
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implementation of the Issuer's stra
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Interest rate fluctuations may adve
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of the Notes. A downgrading of the
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Noteholders are exposed to the risk
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Holders of Fixed Rate Notes are exp
Page 29 and 30: Investors have to rely on the funct
Page 31 and 32: epresented by a global note in bear
Page 33 and 34: exclusive jurisdiction. Consumers w
Page 35 and 36: Terms and Conditions [Title of Note
Page 37 and 38: [insert definition of EURIBOR and E
Page 39 and 40: [in the case of "Actual/365" or "Ac
Page 41 and 42: § 9 Taxation All payments of princ
Page 43 and 44: [In case of early redemption on the
Page 45 and 46: 17. 18. (iii) Partial Redemption: (
Page 47 and 48: General DIE ERSTE ÖSTERREICHISCHE
Page 49 and 50: VolkswagenStiftung 2,457,544,000 (M
Page 51 and 52: The development objective of ERSTE
Page 53 and 54: financial services by other banks d
Page 55 and 56: In the case that funds will be requ
Page 57 and 58: ("AGM") not to pay a dividend for t
Page 59 and 60: Member Boris Marte Other positions:
Page 61 and 62: Member Maximilian Hardegg Privatsti
Page 63 and 64: Sparkassen AG, with the procedure i
Page 65 and 66: The foundation’s auditor is the a
Page 67 and 68: Other assets 7.132 6.898 Subscribed
Page 69 and 70: Revenue reserves 197,597 203,784 -3
Page 71 and 72: The English translation of the repo
Page 73 and 74: MATERIAL CONTRACTS Since 31 Decembe
Page 75 and 76: the taxation of financial instrumen
Page 77 and 78: Private foundations pursuant to the
Page 79: CZECH REPUBLIC General Czech tax im
Page 83 and 84: LUXEMBOURG The following summary is
Page 85 and 86: Luxembourg income tax on interest a
Page 87 and 88: Capital gains Income from the sale
Page 89 and 90: OFFER AND SUBSCRIPTION The Programm
Page 91 and 92: SELLING RESTRICTIONS This Prospectu
Page 93 and 94: (ii) the published annual report an
Page 95 and 96: LIBOR means the London Inter-bank O
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DIE ERSTE österreichische Spar-Casse ... - ERSTE Stiftung

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