Österreichische Volksbanken-Aktiengesellschaft ... - Volksbank AG

Under the effective Hungarian law gift tax applies to the donation of bonds transferred in Hungary.
The taxable base is the net value of the gift. The applicable rates depend on the relationship
between the donor and the recipient. The groups are the same as determined for inheritance
tax. The applicable rates are as follows.
For the first group (children / spouse / parents) the applicable rates are 11 per cent., 18 per cent.,
21 per cent. depending on the value of the security.
If another close relative is the recipient, the applicable rates are 15 per cent., 21 per cent. and 30
per cent. accordingly.
In case of the third group (others) the applicable rates are 21 per cent., 30 per cent. and 40 per
cent. respectively.
Note that from 2007 onwards certain gifts (e.g. donation of bonds) between corporate entities is
also subject to gift tax under the general rules, with a preferential 21% applicable for closely
related entities.
Taxation in the Czech Republic
Czech (corporate) income taxation regarding the Notes (except warrants)
Tax Residents
Payments of interest on Notes to individuals with unlimited income tax liability in the Czech
Republic holding Notes as a non-business asset are subject to taxation in the Czech Republic.
If interest is paid out by an Czech tax payer, then such payments are subject to a withholding tax
of 15 per cent. ("Czech withholding tax"); no additional income tax is levied over and above the
amount of tax withheld (final taxation pursuant to sec. 5(5) of the Czech Income Tax Act).
The difference between the nominal value paid for a bond and its issue price at the time of issue
are considered as interest income accruing from capital pursuant to sec. 8 of the Czech Income
Tax Act, subject to withholding tax at rate of 15 per cent. (please note that in the case of repurchase
before maturity the redemption price shall be used instead of the nominal value).
Where the interest are made on Notes originated from sources abroad or the income on difference
between the nominal value paid for a bond and its issue price at the time of issue is originated
from sources abroad, this income including tax withheld abroad and not reduced by the
relevant expenses may constitute a partial tax base taxed by 15 per cent.
Capital gains (i.e. the difference between the sales price and the acquisition cost of the bonds)
realized upon sale of the Notes within six months after acquisition are subject to income tax at a
marginal rate of up to 32 per cent. pursuant to sec. 10 of the Czech Income Tax Act; capital
gains from the Notes sold after six months after its acquisition are tax-free pursuant to sec. 4 (1)
(w) of the Czech Income Tax Act.
Payments of interest on Notes to individuals with unlimited income tax liability in the Czech
Republic holding Notes as a business asset are subject to taxation in the Czech Republic.
If interest is paid out by an Czech tax payer, then such payments are subject to a withholding tax
of 15 per cent. ("Czech withholding tax"); no additional income tax is levied over and above the
amount of tax withheld (final taxation pursuant to sec. 5 (5) of the Czech Income Tax Act).
The difference between the nominal value paid for a bond and its issue price at the time of issue
are considered as income accruing from capital pursuant to sec. 8 of the Czech Income Tax Act
subject to withholding tax at the rate of 15 per cent. (please note that in the case of repurchase
before maturity the redemption price shall be used instead of the nominal value).
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