Erste Bank JPMorgan Merrill Lynch International

applicable restrictions and limitations that may vary depending upon such holder’s circumstances.
Austrian taxes withheld in excess of the Tax Treaty rate for which a refund is available are not eligible
for credit against a U.S. Holder’s U.S. federal income tax liability. See “— Taxation in Austria—Austrian
Withholding Tax—Dividends—Non Resident Shareholders” above for a discussion of how a U.S. Holder
may obtain a refund. Dividend income generally will constitute foreign-source “passive category”
income or in the case of certain U.S. Holders, foreign-source “general category” income for foreign tax
credit purposes. U.S. Holders should consult their own tax advisers to determine whether they are
subject to any special rules that limit their ability to make effective use of foreign tax credits. A
U.S. Holder that does not elect to claim a foreign tax credit may instead claim a deduction for Austrian
income tax withheld, but only for a year in which the holder elects to do so with respect to all foreign
income taxes.
Special rules govern the manner in which accrual basis taxpayers are required (or may elect) to
determine the U.S. dollar amount of taxes withheld in a foreign currency that is eligible for a foreign
tax credit. Accrual- basis taxpayers therefore should consult their own tax advisors regarding the
requirements and elections applicable in this regard.
Sale or Other Disposition of Shares
A U.S. Holder will generally recognize capital gain or loss on the sale or other disposition of
shares, which will be long-term capital gain or loss if the holder has held such shares for more than
one year. The amount of the U.S. Holder’s gain or loss will be equal to the difference between the
amount realized on the sale or other disposition and such holder’s tax basis in the shares, as
determined in U.S. dollars. Any gain or loss will generally be U.S.-source gain or loss for foreign tax
credit purposes. For non-corporate U.S. Holders, any capital gain will generally be subject to
U.S. federal income tax at preferential rates provided certain holding period requirements are met.
The deductibility of a capital loss is subject to limitations.
A U.S. Holder that receives Euro on the sale or other disposition of shares will realize an amount
equal to the U.S. dollar value of the Euro on the date of sale or other disposition (or in the case of
cash-basis and electing accrual-basis taxpayers, the settlement date, provided that the shares are
traded on an established securities market). An accrual-basis U.S. Holder that does not elect to
determine the amount realized using the spot rate on the settlement date will recognize exchange gain
or loss (taxable as U.S. source ordinary income or loss) equal to the difference (if any) between the
U.S. dollar value of the amount received based on the spot exchange rates in effect on the date of
sale or other disposition and the settlement date. A U.S. Holder will have a tax basis in the Euro
received equal to the U.S. dollar value of the Euro on the settlement date. Any exchange gain or loss
realized on a subsequent conversion of the Euro into U.S. dollars will be U.S.-source ordinary income
or loss.
Passive Foreign Investment Company Considerations
Based on the nature of its business, the Issuer believes that it was not a passive foreign
investment company (a “PFIC”) for U.S. federal income tax purposes for its 2007 taxable year and
does not expect to become a PFIC for the foreseeable future. However, since PFIC status depends
upon the composition of a company’s income and assets and the market value of its assets (including,
among others, less than 25% owned equity investments) from time to time, and the nature of its
business, there can be no assurance that the Issuer will not be considered a PFIC for any taxable
year. If the Issuer were treated as a PFIC for any taxable year during which a U.S. Holder directly or
indirectly held a share, certain adverse U.S. federal income tax consequences could apply to such
holder.
Information Reporting and Backup Withholding
Payment of dividends and sales proceeds that are made within the United States or through
certain U.S.-related financial intermediaries generally are subject to information reporting and to
backup withholding unless the U.S. Holder is a corporation or other exempt recipient or, in the case of
backup withholding, the holder provides a correct taxpayer identification number and certifies that no
loss of exemption from backup withholding has occurred. The amount of any backup withholding from
a payment to a U.S. Holder will be allowed as a credit against the holder’s U.S. federal income tax
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