Erste Bank JPMorgan Merrill Lynch International

tax consequences that may be relevant to a holder in light of the holder’s particular circumstances or
to holders subject to special rules, such as:
certain financial institutions;
insurance companies;
dealers and certain traders in securities or foreign currencies;
persons holding shares as part of a hedge, straddle, conversion or integrated transaction;
persons whose functional currency for U.S. federal income tax purposes is not the U.S. dollar;
partnerships or other entities classified as partnerships for U.S. federal income tax purposes;
regulated investment companies or real estate investment trusts;
persons liable for the alternative minimum tax;
tax-exempt organizations; or
persons that own or are deemed to own 10% or more of the Issuer’s voting stock.
This discussion is based on the Code, administrative pronouncements, judicial decisions, final,
temporary and proposed Treasury regulations and the income tax treaty between the United States
and Austria (the “Tax Treaty”), all as of the date hereof. These laws are subject to change, possibly on
a retroactive basis. Prospective purchasers should consult their own tax advisers concerning the
U.S. federal, state, local and non-U.S. tax consequences of purchasing, owning and disposing of
shares in their particular circumstances.
As used herein, a “U.S. Holder” means a beneficial owner of a share that is eligible for benefits of
the Tax Treaty and is, for U.S. federal income tax purposes: (i) a citizen or resident of the
United States; (ii) a corporation, or other entity taxable as a corporation, created or organized in or
under the laws of the United States or any political subdivision thereof; or (iii) an estate or trust the
income of which is subject to U.S. federal income taxation regardless of its source.
This discussion assumes that the Issuer is not, and will not become, a passive foreign investment
company (as discussed below).
Taxation of Subscription Rights
A U.S. Holder will not have any U.S. federal income tax consequences as a result of the receipt
exercise or expiration of the Subscription Rights. A U.S. Holder that exercises Subscription Rights
generally will have a tax basis in the New Shares equal to the Subscription Price paid for the New
Shares.
Taxation of Distributions
Distributions received by a U.S. Holder on shares, other than certain pro rata distributions of
shares to all shareholders, will constitute foreign-source dividend income to the extent paid out of the
Issuer’s current or accumulated earnings and profits (as determined for U.S. federal income tax
purposes). Because the Issuer does not maintain records of earnings and profits for U.S. federal
income tax purposes, it is expected that distributions will generally be reported to U.S. Holders as
dividends. The amount of the dividend will include any amounts withheld in respect of Austrian taxes.
The amount of the dividend a U.S. Holder will be required to include in income will equal the U.S. dollar
value of the euro, calculated by reference to the exchange rate in effect on the date the payment is
received by the holder, regardless of whether the payment is converted into U.S. dollars on the date
of receipt. If a U.S. Holder realizes gain or loss on a sale or other disposition of euro after the date of
receipt, such gain or loss will be U.S.-source ordinary income or loss. Corporate U.S. Holders will not
be entitled to claim the dividends-received deduction with respect to dividends paid by the Issuer.
Subject to applicable limitations, dividends received by certain non-corporate U.S. Holders in taxable
years beginning before January 1, 2011 may be taxable at a maximum rate of 15%. Non-corporate
U.S. Holders should consult their own tax advisers regarding the availability of these favorable rates in
light of their own particular situation.
Austrian taxes withheld from cash dividends on shares at a rate not exceeding the rate provided
in the Tax Treaty will be creditable against a U.S. Holder’s U.S. federal income tax liability, subject to
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