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

If the Notes are attributed to the permanent establishment of a non-Czech tax resident, a
different tax regime applies. In general, the gain is taxed as a regular business profit of the
permanent establishment in the Czech Republic.
Inheritance and gift tax
Subject to gift tax is the donation of the Notes located in the Czech Republic to non-resident
individuals and corporations. In case the donor is a Czech resident, the tax is payable by the
donor; if the donor is a non-resident, the tax is payable by the non-resident donee. Czech law
is applicable only if a treaty does not provide otherwise.
Subject to inheritance tax are all Notes inherited by non-residents in case the deceased was a
citizen of the Czech Republic. If the deceased was not a citizen of the Czech Republic, nonresidents
are liable to inheritance tax only on Notes located in the Czech Republic at the time
of the death of the deceased. This applies unless an international treaty provides otherwise.
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 100% tax exemption may be applied in specific cases, such as succession
by direct relatives and spouses.
Implementation of the EU Savings Directive
The Czech Republic has implemented the EU Savings Directive. If the payments qualify as
interest or other similar income under the EU Savings Directive, a Czech paying agent will
collect certain specified details in respect of the payments of interest and other similar income
mediated by the Czech paying agent and the Czech Republic will provide this information to
the tax authorities in other EU Member States. The same regime also applies in respect of
certain non-EU countries and dependent territories, such as Switzerland, San Marino,
Monaco, Andorra and Liechtenstein.
Other taxes
No other taxes are levied in the Czech Republic on the acquisition, sale or other disposal of
the Notes.
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