'
|
|
- Andrew Sharp
- 8 years ago
- Views:
Transcription
1 CLASSIFICATION SHEET This document relates to the following request: 10 March 2010 References: SES/MLFO/TSDK/ AEVF/Q M-NANN Samisa Sari - Fiscal number to be provided when available Ace Investment Scandinavia BV - Fiscal number to be provided upon migration Key topics: Liquidation I Migration I Holding structure I Classes of shares I PPL I Interest Free Loan I I FU!_l_~~!!_~UIT~~y J 2. Name of the advisor : PwC 3. Corpo!ate group's name, or fund sponsor: Ace Group 4. Name of the project: Ac<;:_ 5. Amount intended to be invested: ~ ~ 6. Date of receipt: ' -BUREAUITTMPOSITION SOC B ffr-fe ' _J
2
3 For the attention of Mr Marius Kohl Administration des Contributions Directes Bureau d' imposition Societes VI 18, rue du Fort Wedell L-2982 Luxembourg PriccwatcrhouscCoopcrs Sociclc ii rcsponsabililc limitcc Rcviscur d'cnlrcpriscs 400, route d'esch B.P L-1014 Luxembourg Telephone Facsimile inf'o@lu.pwc.com l 0 March 2010 BUREAU D'IMPOSITION SOC. 6 ENTREE References: SES/MLFO/TSDK/ AEVF/Q44 l 0003M-NANN Ace Group - Luxembourg restructuring Dear Mr Kohl, In our capacity of tax consultant of Ace Group, we discussed in our meeting dated January 28, 2010, the tax treatment applicable to the transactions foreseen by our client. This letter aims at confirming the conclusions reached during this meeting and will serve as a basis for the preparation of the tax return of the Luxembourg companies involved. A. Background and facts A.1 Background The ultimate beneficial owner of the Ace structure is Fredrick Alama (hereafter referred to as "FA"). FA is currently tax resident in Sweden. 2 FA is the sole shareholder of the Dutch resident company Ace Investment Scandinavia BV (hereafter referred to as "Ace"). 3 Ace is holding numerous subsidiaries mainly in Sweden, Spain, Canada, the Netherlands and the United States which invest in various businesses. R.C.S. Luxembourg B TYA LU
4 4 Please find the current simplified as well as the post-restructuring chart of the Ace structure in Appendix 1. A.2 Facts 5 The Ace group contemplates to reorganize the group holding structure by interposing a newly incorporated Luxembourg company, i.e. Samisa S.a r.1. (hereafter referred to as "LuxCo") and by migrating I liquidating Acc. 6 The various steps of the contemplated restructuring relevant from a Luxembourg perspective are as follows: Step 1. Mr Alama (hereafter referred to as "FA") incorporates a Luxembourg company ("Lux Co") by way of share capital divided into 10 classes of shares: 1 ordinary shares class and 9 preferred shares classes (Classes A to I) economically linked to a specific period of time. Step 2. FA sells the shares in Ace Scandinavia Investment BV (hereafter referred to as "Ace") to LuxCo at acquisition cost in exchange for a PPL of SEK 421,791; Step 3. Ace transfers its central administration from The Netherlands to Luxembourg; Step 4. Ace is liquidated into LuxCo. B. Applicable Luxembourg Tax Regime B.1 Tax residency 7 Pursuant to article 159 of the Luxembourg income tax law ("LITL"), a company is treated as tax resident in Luxembourg if either its registered office (i.e., statutory seat) or its central administration is located in Luxembourg. 8 FA will form a new Luxembourg resident company, i.e. Lux Co. Lux Co will be incorporated under the form of a S.a r.i. and will have its statutory seat located in Luxembourg. 9 LuxCo will have its place of central administration in Luxembourg since its shareholders' meetings and its board meetings will be held in Luxembourg, its main management decisions will effectively be taken in Luxembourg and its accounting will be done and kept in Luxembourg. I 0 Ace will transfer its effective place of management (central administration) to Luxembourg. Its shareholders' meetings and board meetings will be held in Luxembourg, the main management decisions will be effectively taken in Luxembourg and its accounting will be done and kept in Luxembourg. (2)
5 11 Therefore, LuxCo and Ace (after migration) will be considered to be Luxembourg tax residents within the meaning of article 159 LITL and within the meaning of the double tax treaties concluded by Luxembourg. Luxembourg tax residency certificates will therefore be delivered by the Luxembourg tax authorities upon request. B.2 Migration of Ace 12 In application of article 35 UTL, a foreign company that moves its central administration to Luxembourg is deemed to have created a new business in Luxembourg and acquires the qualification of a resident taxpayer. Upon migration to Luxembourg, Ace will establish a tax balance sheet as per the date of the transfer of its central administration, in which all its assets and liabilities will be valued at their fair market value ("FMV"). 13 However, in accordance with the principles enacted in the administrative circular dated March 2009, further to the migration of a foreign company in Luxembourg, the initial acquisition dates and the initial acquisition prices of the subsidiaries held by the migrated company, must be used for the determination of the threshold required for the application of the Luxembourg participation exemption regime as laid down by both Articles 166 and 147 LITL. B.3 Liquidation of Ace 14 By virtue of Article 170 (2), and by analogy with the provision of the EC Merger Directive, the liquidation of Ace may be carried out at book value considering that the provisions of the above Article arc met (i.e. (i) Ace transfers all its assets and liabilities to LuxCo, a fully taxable Luxembourg resident company, (ii) the consideration of the transaction is the cancellation of the participation held by LuxCo in Ace and (iii) the unrealized profits which have escaped taxation due to the effects of this provision will be open to taxation in Luxembourg in the future). 15 Consequently, Ace should not realize any capital gains on the transfer of all its assets and liabilities to LuxCo and therefore should not be taxed. 16 LuxCo will continue the book values (i.e., for accounting and tax purposes) and the holding periods of the assets and liabilities as recorded previously by Ace. 17 However, as per Article 171 (1) LTTL, although the assets and liabilities of Ace will be transferred at book value, LuxCo will be deemed to realize its participation in Ace at market value for tax purposes. 18 Nevertheless, according to Article 171 (3) LITL, as Ace will be 100% held by LuxCo, any potential capital gains realized upon the participation in Ace will be exempt in the hand of LuxCo, even without having fulfilled the 12 months holding period is not met. (3)
6 B.4 Profit Participating Loan ("PPL") 19 LuxCo will issue a PPL to FA, initially to acquire Ace (at acquisition value). Further to the liquidation of Ace, the PPL will finance the various investments in subsidiaries held by LuxCo. 20 PPL will be regarded as debt for corporate income tax, municipal business tax and net wealth tax purposes. Interest on the PPL will be tax deductible in accordance with article 45 (1) LITL, unless article 45 (2) LITL or article 166 (5) LITL is applicable. 21 Any interest LuxCo shall pay under the PPL will not be subject to any Luxembourg withholding tax. 22 Please see Appendix 3 for a summary of terms of the PPL, and a more detailed tax analysis of the PPL. 23 The sale of the shareholding in Ace by FA to Lux Co carried out at acquisition cost against the PPL will not create any Luxembourg tax consequences (i.e. the variable interest on the PPL will still repatriate 85% of LuxCo's adjusted profits). The whole transaction can be viewed as can-ied out at arm's length particularly given the mechanism of the PPL. B.5 Classes of shares 24 LuxCo's by-laws provide for its share capital to be divided into 1 ordinary share class and 9 preferred share classes [class A to l). The redemption of one entire class of shares followed by its cancellation shall be regarded as a partial liquidation within the meaning of article 101 LITL. 25 Article l 01 LITL provides that income resulting from a partial liquidation shall be regarded as an income derived from the realization of the participation and not as a dividend. Accordingly, article 97 (3) d LITL provides that such income is not subject to the Luxembourg withholding tax laid down in article 146 LITL. 26 As a consequence, the redemption of a whole class of share by LuxCo, followed by a corresponding reduction of its share capital will not be subject to any withholding tax in Luxembourg. 27 Please refer to Appendix 4 for a complete analysis of the tax treatment of share classes. (4)
7 B.6 Debt to equity ratio 28 Given that the fixed and variable interest on the PPL will be discounted by 15%, Lux Co will comply with the 85: 15 debt-to-equity ratio requirement applied in Luxembourg's practice for the intragroup financing of participations. 29 Accordingly, interest payments on the PPL will remain deductible and will not be re-characterized into dividend distributions. No withholding tax should hence apply to interest payment on the PPL. B.7 Functional Currency 30 Swedish Crown (SEK) will be the functional currency of LuxCo for accounting and tax purposes as of its date of incorporation. 31 Therefore, the tax returns will be prepared on the basis of the accounts of LuxCo in SEK and the annual positive taxable result will be converted into EUR using the year end EUR/SEK market rate. * * * (5)
8 We respectfully request that you confirm the tax treatment of the situation described above or that you provide us with your remarks, if any. We remain at your disposal should you need any further information and would like to thank you for the attention that you will give to our request. Yours sincerely, Serge Partne Appendices: Appendix 1: Appendix 2: Appendix 3: Abridged structure charts both prior and after the restrncturing Tax treatment of the Profit Participating Loans ("PPL'') Luxembourg tax treatment of the classes of shares of Lux Co This tax advice is based on the facts as presented to PricewaterhouseCoopers Sari as at the date the advice was given. The advice is dependent on specific facts and circumstances and may not be appropriate lo another party than the one.for which it was prepared. This tax advice was prepared with only the interests of PwC Stockholm's client, Ace, in mind, and was not planned or carried out in contemplation of any use by any other party. PricewaterhouseCoopers Sari, its partners, employees and or agents, neither owe nor accept any duty of care or any responsibility to any other party, whether in contract or in tort (including without limitation, negligence or breach of statutory duty) however arising, and shalt not be liable in respect of any loss, damage or expense of whatever nature which is caused to any other party. (6)
9 Appendix 1 A Current (abr idged) structure chart Mr. F. Alama 100% Ace Investment Scandinavia BV (The Netherlands) I I Subsidiaries - >--- (7)
10 B Post-restructuring (abridged) structure chart Mr. F. Alama Classes of shares 100% PPL Lux Co (Luxembourg) Subsidiaries (8)
11 Appendix 2 Tax treatment of the Profit participating loans ("PPL") A Main features of the PPL The PPL issued by LuxCo to FA will have the following characteristics: PPL Characteristics Repayment date Voting Rights: Yield Maturity date of 20 years No nterest on the PPL will be a fixed and a variable interest which shall correspond to A fixed interest rate of 0.85 % per annum (i.e., 1 % discounted by 15%) of the aggregate outstanding principal amount of the PPL; A variable interest equal to, on an accrued basis, 85% of the net accounting profit deriving from the investment, as reflected in the annual accounts, before taxes, deducting the adjusted losses derived from the investment, the fixed interest and a prorate of the overhead costs. Subordination : No PPL Amount: SEK 421,791 Partialff otal Redemption: Early redemption: Limited recourse: Transferability: At the Repayment date LuxCo shall be entitled, at any time and at its election, to repay all or part of the aggregate outstanding principal amount of the PPL together with all accrued and unpaid interest in relation thereto; No Free (at the option of the lender) (9)
12 B A Tax treatment of the Profit participating interest Tax Classification as debt According to the commentaries to the income tax law (commentaries included in "Projet de Loi No 571 " (1955) on the former Article 114 LITL (now Article 97 LITL) on income from participation, where a profit participating instrument bears a minimum fixed return, payable even when the company is in a loss position, and provided the principal amount of the loan is repayable before the reimbursement of the company's share capital, the profit participating instrument should continue to be treated as a debt for Luxembourg tax purposes. In the case at hand, the fixed interest will accrue without taking into consideration whether the company is in a profit or loss position. Consequently, the PPL granted by FA to LuxCo will be qualified as debt for both net wealth tax purposes and for corporate income tax purposes and interest thereon will be deductible under the same conditions as apply to fixed interest debts, notably the application of the article 45(2) LITL and article 166(5) LITL. B Characterization of PPL interest payments Experts have examined the possibility that the definition of "dividends" given by the Luxembourg income tax law could include payment qualified as interest. According to their analysis, the key criteria to qualify a payment as a dividend, rather than interest are: the entitlement to ongoing profit (including profit reserves); and the entitlement to the liquidation proceeds. Under this interpretation, the payment of an amount not relating to the profit of the borrower, nor to its liquidation proceeds, may not be considered as a dividend. In the case at hand, the PPL variable rate of interest will be dependent on the income realised by LuxCo before Luxembourg tax (and not on the profit after tax), and therefore, any such interest payments will be treated as interest for Luxembourg tax purposes and as a consequence exempt from withholding tax (see below). C Withholding tax treatment on PPL interest payments Article 146(1)-3 of the LITL provide for the application of a withholding tax upon payment of interest arising from participating bonds or other similar securities. Interest payments are only subject to a 15% withholding tax in Luxembourg if the following conditions are satisfied: The loan is structured in the form of bonds or other similar securities; and As well as the fixed interest, supplementary interest varying according to the amount of profits otherwise distributed is paid, unless the said supplementary interest is stipulated simultaneously with a momentary decrease of the fixed interest. (10)
13 In the present case, the debts are structured as profit part1c1pating loans (not profit participating bonds) and the participating interest does not depend on distributed profit. Therefore, interest on the PPL paid by LuxCo to FA will not be subject to any withholding tax. In addition, articles 97( 1 )-2 and 146(1 )-2 LITL provide for a withholding tax when a profit participating return is paid to a silent partner ("bailleur de fonds"). The PPL holder cannot be assimilated to silent partners within the meaning of the above-mentioned provisions. Indeed, there is no common interest/goal between the PPL holder and the borrowing company. Based on the above, no withholding tax on investment income will be due on interest paid under any of the PPL (be it either on the ground of article 146 (1 )-3 LITL or of article 146 (1)-2 LITL). ( 11)
14 Appendix 3 Luxembourg tax treatment of the classes of shares of Lux Co 1 Description of issued shares and redemption mechanism In December 2009, LuxCo issued 125 ordinary shares and 9 classes of preferred shares (i.e. class A, B, C, D, E, F, G, H and I) being a total of 134 shares with all shares having a nominal value of EUR l 00 each. Thus, the total share capital of LuxCo amounts to EUR 13, Each share confers an identical voting right and each shareholder has voting rights commensurate to his shareholding. Each share shall rank pari passu with every other share and shall entitle its owner to equal rights to any distribution of dividends. Each class of preferred shares is however economically linked to a specific period of time and gives right to the holders thereof pro rata to their holding threshold in such class, in case of redemption of such class, to the available amount of the relevant period to which the preferred share class relates. 3 The period for class A preferred shares is the period starting on the day of incorporation and ending on the Interim Account Date for the Class A Interim Accounts (the "Class A Period") to be established as from January 20 l 0 onwards whereas the Period for Class B Preferred Shares is the period starting on the day after the Class A Period and ending on the Interim Account Date for Class B Interim Accounts (the "Class B Period"), etc. 4 It should also be noted that in the event a Preferred Class of Shares has not been repurchased and cancelled within the relevant Class Period, the holders of such class shall become entitled, in case of a redemption and cancellation of the relevant class, to the Available Amount for a new period (the ''New Period") which shall start of the date after the last Class Period (or as the case may be the immediately preceding New Period of another class) and end on the Interim Account Date of the Interim Accounts prepared for the repurchase and cancellation of such Class of Preferred Shares, provided that if there is no Interim Account Date for such Class, the Period of such Class will end on the last day of the third month following the first year end after the start date of such New Period. The first New Period shall start on the date after the Class I Period and the Classes of Preferred Shares not repurchased and not cancelled in their Period shall come in the order of Class A to Class I (to the extent not previously repurchased and cancelled). 5 The share capital of the company may be reduced through cancellation of shares including by the cancellation of one or more entire class(es) of preferred shares through the repurchase and cancellation of all the shares in issue in such class( es). (l2)
15 6 In the event of a reduction of share capital through the repurchase and the cancellation of one or more class( es) of preferred shares, the holders of shares of the repurchased and cancelled class(es) of preferred shares shall receive from the company an amount equal to the cancellation value per share for each share of the relevant class( cs) held by them and cancelled. 2 Tax treatment of the redemption of shares 8 The different classes of shares issued by LuxCo provide for different economic rights. 9 Under Article 101 (1) of LJTL, profits derived by the holder of a qualifying participation from the partial liquidation of a Luxembourg joint-stock company is considered as income derived from the realization of the participation, within the meaning of Article 101 LITL. I 0 According to Article 101 (2) LITL, in case of redemption of a participation followed by a consecutive reduction of share capital, the company is deemed partially liquidated for a corresponding proportion. 11 In the case at hand, the redemption of a whole class of shares by Lux Co followed by a proportional reduction of the share capital of the said company would be regarded as a partial liquidation of the entity (Article I 01 (1) LITL) and thus as a realization by the investors of a part of their participation in this company. Consequently, since income derived from the realization of a shareholding is not included by Article 146 LlTL within the categories of capital income subject to Luxembourg withholding tax, the redemption of a whole class of shares by LuxCo followed by a proportional reduction of its share capital will not be subject to withholding tax in Luxembourg. (13)
16
17 LE GOUVERNEMENT DU GRAND- DUCHE DE LUX EMBOURG Administration des contributions directes Bureau d'imposition Societes 6 For the attention of Serge Saussoy PricewaterhouseCoopers 400, route d'esch B.P L Luxembourg Companies involved : Samisa Sari - Fiscal number in process Ace Investment Scandinavia BV - Fiscal number in process 2 4 HARS 2010 Dear Sir, Further to your letter dated March 10, 2010 and referenced SES/MLFO/TSDK/AEVF/Q M-NANN relating to the transactions that Ace Group would like to conduct, I find the contents of said letter to be in compliance with current tax legislation and administrative practice. It is understood that my above confirmation may only be used within the framework of the transactions contemplated by the above-mentioned letter and that the principles described in your letter shall not apply ipso facto to other situations. 18, rue du Fort Wedell Luxembourg Tel.: (352) Fax: (352) Adresse postale L-2982 Luxembourg
18
CLASSIFICATION SHEET. Client(s) (Fiscal number(s): This document relates to the following request: 21May2008. References: LIE/SHKN/RAT NQ3908015M-SEBD
CLASSIFICATION SHEET This document relates to the following request: 21May2008 References: LIE/SHKN/RAT NQ3908015M-SEBD Client(s) (Fiscal number(s): Tiger Global Private Investment Partners V, L.P. Tiger
More informationREE CLASSIFICATION SHEET. This document relates to the following request: BUREAU D'IMPOSITION SOC. 6. 11 November 2009
CLASSIFICATION SHEET This document relates to the following request: 11 November 2009 BUREAU D'IMPOSITION SOC. 6 REE References: GPI/R730900 I M-FOMO Rockspring Property Investment Managers Ltd TransEuropean
More informationI I I 1 6 JUIL. 2010. References: AEJE/CNWU/R731 OOOlM-IAPI CLASSIFICATION SHEET. Rockspring Property Investment Managers Ltd Project Parinor
CLASSIFICATION SHEET This document relates to the following request: 16 July 2010 References: AEJE/CNWU/R731 OOOlM-IAPI Rockspring Property Investment Managers Ltd Project Parinor LuxCo 1 S.a r.i. Lux
More information- -- ENTREE. This document relates to the following request: November 11th. 2009. References: VCO/ A YHA/ AUBY /Bl 209002M-AEDT CLASSJFICA TION SHEET
CLASSJFICA TION SHEET This document relates to the following request: BUREAU D'IMPOSITION SOC. 6 ENTREE November 11th. 2009 References: VCO/ A YHA/ AUBY /Bl 209002M-AEDT 1. Key topics: Factorin~ activities,
More informationCross Border Tax Issues
Cross Border Tax Issues By Reinhold G. Krahn December 2000 This is a general overview of the subject matter and should not be relied upon as legal advice or opinion. For specific legal advice on the information
More informationFINAL TERM SHEET. Scatec Solar ASA Senior Unsecured Bond Issue 2015/2018 (the Bonds or the Bond Issue )
11 November 2015 FINAL TERM SHEET Scatec Solar ASA Senior Unsecured Bond Issue 2015/2018 (the Bonds or the Bond Issue ) ISIN: NO001 075229.8 Issuer: Group: Currency: Borrowing Amount: Coupon Rate: Scatec
More informationFIRSTSERVICE CORPORATION NOTICE OF REDEMPTION & CONVERSION TO ALL REGISTERED HOLDERS OF OUTSTANDING 7% CUMULATIVE PREFERENCE SHARES, SERIES 1
FIRSTSERVICE CORPORATION NOTICE OF REDEMPTION & CONVERSION TO ALL REGISTERED HOLDERS OF OUTSTANDING 7% CUMULATIVE PREFERENCE SHARES, SERIES 1 To: All Registered Holders of Outstanding 7% Cumulative Preference
More informationInformation regarding share split and redemption of shares in AB Volvo 2007
Information regarding share split and redemption of shares in AB Volvo 2007 The share split and redemption procedure in summary Table of contents 2 The share split and redemption procedure in summary 3
More informationPRIVATE WEALTH MANAGEMENT COMPANIES
PRIVATE WEALTH MANAGEMENT COMPANIES (SPFs) www.bdo.lu 2 Private Wealth Management Companies (SPFs) TABLE OF CONTENT FOREWORD 3 1. INTRODUCTION 4 2. ACTIVITIES OF AN SPF 2.1 Permitted activities...5 2.2
More information[SIGNATURE PAGE FOLLOWS]
[ ] TERM SHEET FOR SUBORDINATED VARIABLE PAYMENT DEBT (DEMAND DIVIDEND) THIS TERM SHEET outlines the principal terms of a proposed financing for [ ] (hereafter, the Company ), a [ ] corporation by [ ]
More informationUnaudited financial report for the. sixt-month period ended 30 June 2015. Deutsche Bahn Finance B.V. Amsterdam
Unaudited financial report for the sixt-month period ended 30 June 2015 Deutsche Bahn Finance B.V. Table of contents Annual report of the directors 3 Balance sheet as at 30 June 2015 4 Profit and loss
More information3 In 2007 the Company notified the Luxembourg tax authorities on the existence of tax losses (our reference: WPl/EEAE/H4207013M-JEGI).
For the attention of Mr Marius Kohl Administration des contributions directes Bureau Societes VI 18, rue du Fort Wedell L - 2982 Luxembourg PricewatcrhouseCoopers Societe a responsabilitc llmitee Reviseur
More informationWLP LAW. II. The Dutch corporate tax system. INVESTING IN INDIA OR THE UNITED STATES OF AMERICA THROUGH THE NETHERLANDS Tax Alert April 2013
INVESTING IN INDIA OR THE UNITED STATES OF AMERICA THROUGH THE NETHERLANDS Tax Alert April 2013 i Tel +31 I. (0)88 Introduction 2001300 Cell +31 (0)6 M The Netherlands is an attractive and advantageous
More informationDESCRIPTION OF THE PLAN
DESCRIPTION OF THE PLAN PURPOSE 1. What is the purpose of the Plan? The purpose of the Plan is to provide eligible record owners of common stock of the Company with a simple and convenient means of investing
More informationASPE AT A GLANCE Section 3856 Financial Instruments
ASPE AT A GLANCE Section 3856 Financial Instruments December 2014 Section 3856 Financial Instruments Effective Date Fiscal years beginning on or after January 1, 2011 1 SCOPE Applies to all financial instruments
More informationFinancial report 2014. Deutsche Bahn Finance B.V. Amsterdam
Financial report 2014 Deutsche Bahn Finance B.V. Table of contents Annual report of the directors 3 Balance sheet as at 31 December 2014 4 Profit and loss account for the year ended 31 December 2014 6
More informationCYPRUS TAX CONSIDERATIONS
TAXATION The following summary of material Cyprus, US federal income and United Kingdom tax consequences of ownership of the GDRs is based upon laws, regulations, decrees, rulings, income tax conventions
More informationInternal Revenue Service
Internal Revenue Service Number: 200750009 Release Date: 12/14/2007 Index Numbers: 368.04-00, 355.01-00 ---------------------- -------------------------------------------------- --------------------------------------
More informationTerm Sheet ISIN: NO 0010672827. FRN Marine Harvest ASA Senior Unsecured Open Bond Issue 2013/2018 (the Bonds or the Loan )
Term Sheet ISIN: NO 0010672827 FRN Marine Harvest ASA Senior Unsecured Open Bond Issue 2013/2018 (the Bonds or the Loan ) Settlement date: Expected to be 12 March 2013 Issuer: Currency: Loan Amount / First
More informationGLOBAL GUIDE TO M&A TAX
Quality tax advice, globally GLOBAL GUIDE TO M&A TAX 2013 EDITION www.taxand.com CYPRUS Cyprus From a Buyer s Perspective 1. What are the main differences among acquisitions made through a share deal versus
More informationBelgium in international tax planning
Belgium in international tax planning Presented by Bernard Peeters and Mieke Van Zandweghe, tax division at Tiberghien Belgium has improved its tax climate considerably in recent years. This may be illustrated
More informationTAXATION OF INTEREST, DIVIDENDS AND CAPITAL GAINS IN CYPRUS
TAXATION OF INTEREST, DIVIDENDS AND CAPITAL GAINS IN CYPRUS LAWS AND DECREES The Income Tax (Amendment) Law of 2005 The Special Contribution for Defence (Amendment) Law of 2004 The Assessment and Collection
More informationTAXATION OF FINANCIAL INSTRUMENTS
2 Ing. Katarína Vavrová Faculty of Business Management University of Economics in Bratislava Investment in securities is influenced not only by the relation between the intrinsic value and market price
More informationSCORPEX INTERNATIONAL, INC.
AUDIT REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM AND CONSOLIDATED FINANCIAL STATEMENTS C O N T E N T S Report of Independent Registered Public Accounting Firm.... 3 Consolidated Balance Sheets...
More informationLuxembourg..Tax Regime. for Intellectual Property Income
Luxembourg.Tax Regime for Intellectual Property Income December 2009 Table of contents 1. Introduction... 2 2. Qualifying IP rights... 3 3. Tax benefits under the IP regime... 3 4. Conditions to benefit
More informationHalf - Year Financial Report January June 2015
Deutsche Bank Capital Finance Trust I (a statutory trust formed under the Delaware Statutory Trust Act with its principle place of business in New York/New York/U.S.A.) Half - Year Financial Report January
More informationRESTATED ARTICLES OF INCORPORATION OF CISCO SYSTEMS, INC., a California Corporation
RESTATED ARTICLES OF INCORPORATION OF CISCO SYSTEMS, INC., a California Corporation The undersigned, John T. Chambers and Larry R. Carter, hereby certify that: ONE: They are the duly elected and acting
More informationShare redemption 2016
Share redemption 2016 Information for shareholders in HiQ International AB (publ) regarding the Board s proposal for a share split and mandatory redemption procedure Background BACKGROUND HiQ International
More informationThe Bank of Nova Scotia Shareholder Dividend and Share Purchase Plan
The Bank of Nova Scotia Shareholder Dividend and Share Purchase Plan Offering Circular Effective November 6, 2013 The description contained in this Offering Circular of the Canadian and U.S. income tax
More information1.1. Opening Remarks. 1.2. Taxes in Cyprus. 1.3. The Process of Tax Audits in Cyprus. 1 Introduction
1 Introduction 1.1. Opening Remarks After your Cypriot company has been audited and filed the tax return, you do not usually expect any additional tax changes. But in reality the tax story of your company
More informationReport and Non-Statutory Accounts
Report and Non-Statutory Accounts 31 December Registered No CR - 117363 Cayman Islands Registered office: PO Box 309 GT, Ugland House, South Church Street, George Town, Grand Cayman, Cayman Islands Report
More informationDIVIDEND REINVESTMENT AND SHARE PURCHASE PLAN OFFERING CIRCULAR
DIVIDEND REINVESTMENT AND SHARE PURCHASE PLAN OFFERING CIRCULAR December 18, 2013 Shareholders should read carefully the entire Offering Circular before making any decision regarding the Dividend Reinvestment
More informationANNUAL REPORT SYNGENTA FINANCE N.V. AMSTERDAM. on the financial statements 31 December 2013
ANNUAL REPORT SYNGENTA FINANCE N.V. AMSTERDAM on the financial statements 31 December 2013 TABLE OF CONTENTS Directors report 3 Financial statements Balance sheet 6 Profit and loss account 8 Cash flow
More informationCOMPANY PRESENTATION OF THE TERMS FOR TRANSATLANTIC S DEBT CERTIFICATES 2013
COMPANY PRESENTATION OF THE TERMS FOR TRANSATLANTIC S DEBT CERTIFICATES 2013 This summary of the terms and conditions for Rederi AB Transatlantic s (publ) (the Issuer ) maximum SEK 140,000,000 senior unsecured
More informationNORTH ASIA RESOURCES HOLDINGS LIMITED
Hong Kong Exchanges and Clearing Limited and The Stock Exchange of Hong Kong Limited take no responsibility for the contents of this announcement, make no representation as to its accuracy or completeness
More informationNATIONAL UNITED RESOURCES HOLDINGS LIMITED 國 家 聯 合 資 源 控 股 有 限 公 司 (Incorporated in Hong Kong with limited liability) (Stock Code: 254)
Hong Kong Exchanges and Clearing Limited and The Stock Exchange of Hong Kong Limited take no responsibility for the contents of this announcement, make no representation as to its accuracy or completeness
More informationANNUAL REPORT SYNGENTA FINANCE N.V. AMSTERDAM. on the financial statements 2012
ANNUAL REPORT SYNGENTA FINANCE N.V. AMSTERDAM on the financial statements 2012 TABLE OF CONTENTS Directors report 3 Financial statements Balance sheet 6 Profit and loss account 8 Cash flow statement 9
More informationwww.pwc.lu The regime governing holding companies in Luxembourg
www.pwc.lu The regime governing holding companies in Luxembourg January 2013 This publication is exclusively designed for the general information of readers and is (i) not intended to address the specific
More informationPreface 2. 1. Incorporation 3. 2. Share Capital 3. 3. Dividends & Distributions 3. 4. Shareholders Suits 3. 5. Protection of Minorities 4
Cayman Islands Company Law & Taxation Contents Preface 2 1. Incorporation 3 2. Share Capital 3 3. Dividends & Distributions 3 4. Shareholders Suits 3 5. Protection of Minorities 4 6. Disposal of Assets
More informationg 230,000,000 DePfa Bank Capital Funding Trust
g 230,000,000 DePfa Bank Capital Funding Trust (a subsidiary of DePfa Bank AG, Wiesbaden, Germany) 7.125% Noncumulative Trust Preferred Securities (Liquidation Preference Amount h 25 per Trust Preferred
More informationishares IV Public Limited Company
ishares IV Public Limited Company (An umbrella investment company with variable capital and having segregated liability between its Funds incorporated with limited liability in Ireland under registration
More informationTHE GRANDE HOLDINGS LIMITED
The Stock Exchange of Hong Kong Limited takes no responsibility for the contents of this announcement, makes no representation as to its accuracy or completeness and expressly disclaims any liability whatsoever
More informationFINANCIAL STATEMENTS. As at May 31, 2013 and 2012
FINANCIAL STATEMENTS As at May 31, 2013 and 2012 INDEPENDENT AUDITORS REPORT To the Shareholders of the Fonds de solidarité des travailleurs du Québec (F.T.Q.) We have audited the accompanying financial
More informationING Groep N.V. 8.50% ING Perpetual Hybrid Capital Securities
PROSPECTUS SUPPLEMENT (To Prospectus dated December 1, 2005) $1,750,000,000 ING Groep N.V. 8.50% ING Perpetual Hybrid Capital Securities We are issuing $1,750,000,000 aggregate principal amount of 8.50%
More informationUnaudited financial report for the six-month period ending 30 June 2015. RWE Finance B.V. s-hertogenbosch, the Netherlands
Unaudited financial report for the six-month period ending 30 June 2015 RWE Finance B.V. s-hertogenbosch, the Netherlands Content Interim report of the directors 3-5 Interim report of the directors 4-5
More informationTax Treatment of Stocklending/Sale and Repurchase (repo) Transactions
Tax Treatment of Stocklending/Sale and Repurchase (repo) Transactions 4.6.13 1. Background The purpose of this manual is to set out a tax treatment, which may be followed for the purposes of corporation
More informationSummary of key differences between Luxembourg and Swedish corporate law, as per 22 June 2011
Summary of key differences between Luxembourg and Swedish corporate law, as per 22 June 2011 Millicom International Cellular S.A. ("Millicom") is a company incorporated and governed under the laws of the
More informationINFORMATION REGARDING PROPOSED REDEMPTION OF SHARES IN BETSSON AB
2015 INFORMATION REGARDING PROPOSED REDEMPTION OF SHARES IN BETSSON AB Betsson AB s core business consists of investing and administering shareholding in companies, which through partners or by themselves,
More informationCERTIFICATE OF DESIGNATION OF PREFERRED STOCK OF LIGHTING SCIENCE GROUP CORPORATION. To Be Designated Series B Preferred Stock
CERTIFICATE OF DESIGNATION OF PREFERRED STOCK OF LIGHTING SCIENCE GROUP CORPORATION To Be Designated Series B Preferred Stock Pursuant to Section 151(g) of the General Corporation Law of the State of Delaware
More informationTerm Sheet for Potential Investment by Strategic Investor
Form: Term Sheet for Potential Investment by Strategic Investor Description: This is a very detailed term sheet for a prospective Preferred Stock investment in a private company, coupled with a strategic
More informationLuxembourg is creating an environment to attract different kind of funds by providing different kinds of vehicle to pool their investments.
APPENDIX A INVESTMENT FUNDS SECTOR IN LUXEMBOURG Luxembourg is creating an environment to attract different kind of funds by providing different kinds of vehicle to pool their investments. Luxembourg offers
More informationTelecom Italia Capital Société Anonyme 12, rue Eugène Ruppert L-2453 Luxembourg. R.C.S. Luxembourg B 77.970
12, rue Eugène Ruppert L-2453 Luxembourg R.C.S. Luxembourg B 77.970 Audited Annual Accounts as at December 31, 2014, which have been authorized by the Board of Directors held on February 27, 2015 Table
More informationUBS (Irl) Fund plc. Supplement dated 2 July 2015 to the Prospectus dated 27 April 2015
UBS (Irl) Fund plc Supplement dated 2 July 2015 to the Prospectus dated 27 April 2015 This Supplement is part of the English language Prospectus (the "Prospectus") dated 27 April 2015 of UBS (Irl) Fund
More informationDutch limited liability company ( BV )
Dutch limited liability company ( BV ) General Besloten vennootschap met beperkte aansprakelijkheid (usually abbreviated BV in the Netherlands) is the Dutch version of a private limited liability company.
More informationStatus of Capital Adequacy
Capital Adequacy Ratio Highlights 204 Status of Consolidated Capital Adequacy of Mizuho Financial Group, Inc. 206 Scope of Consolidation 206 Consolidated Capital Adequacy Ratio 208 Risk-Based Capital 210
More informationFRS1 FINANCIAL REPORTING STANDARDS ACCOUNTING STANDARDS BOARD OCTOBER 1996 FRS 1 (REVISED 1996)
ACCOUNTING STANDARDS BOARD OCTOBER 1996 FRS 1 (REVISED 1996) Financial Reporting Standard 1 (Revised 1996) is set out in paragraphs 1-50. The Statement of Standard Accounting Practice set out in paragraphs
More informationALTRIA GROUP, INC. CHAIRMAN OF THE BOARD NEW YORK, NEW YORK 10017. March 20, 2007. Dear Altria Shareholder:
ALTRIA GROUP, INC. LOUIS C. CAMILLERI 120 PARK AVENUE CHAIRMAN OF THE BOARD NEW YORK, NEW YORK 10017 Dear Altria Shareholder: March 20, 2007 As you know, on January 31, 2007, the Board of Directors of
More information350,000,000 Non-cumulative Trust Preferred Securities (Liquidation Preference Amount of 50,000 per Trust Preferred Security)
Hypo Real Estate International Trust I Wilmington, Delaware, United States of America (a wholly-owned subsidiary of Hypo Real Estate Bank International AG, Stuttgart, Federal Republic of Germany) 350,000,000
More informationNOTICE OF JOINT SHAREHOLDERS MEETING
SOCIETE GENERALE A French limited liability company with share capital of EUR 542 691 448,75 Head office: 29, boulevard Haussmann 75009 Paris 552 120 222 R.C.S. Paris NOTICE OF JOINT SHAREHOLDERS MEETING
More informationwww.fondsftq.com FINANCIAL STATEMENTS A S AT M AY 3 1, 2 0 1 1 A N D 2 0 1 0
www.fondsftq.com FINANCIAL STATEMENTS A S AT M AY 3 1, 2 0 1 1 A N D 2 0 1 0 INDEPENDENT AUDITORS REPORT To the Shareholders of the Fonds de solidarité des travailleurs du Québec (F.T.Q.) We have audited
More informationTERNIUM S.A. SOCIÉTÉ ANONYME AUDITED ANNUAL ACCOUNTS AS AT DECEMBER 31, 2014
TERNIUM S.A. SOCIÉTÉ ANONYME AUDITED ANNUAL ACCOUNTS AS AT DECEMBER 31, 2014 29, Avenue de la Porte-Neuve, 3rd floor L-2227 Luxembourg R.C.S. Luxembourg B-98-668 Index to the Annual Accounts 3 5 6 7 Audit
More informationPLEASE NOTE. For more information concerning the history of this Act, please see the Table of Public Acts.
PLEASE NOTE This document, prepared by the Legislative Counsel Office, is an office consolidation of this Act, current to May 30, 2012. It is intended for information and reference purposes only. This
More informationLuxembourg holding companies: competitive and tax-efficient
Luxembourg holding companies: competitive and tax-efficient June 2009 Table of contents 1. Introduction...3 2. Standard holding company (SOPARFI)...3 3. Double taxation treaties...3 4. Registration taxes...3
More informationCAPITALAND LIMITED (Incorporated in the Republic of Singapore) Company Registration No.: 198900036N
CAPITALAND LIMITED (Incorporated in the Republic of Singapore) Company Registration No.: 198900036N ANNOUNCEMENT CONVERTIBLE BONDS DUE 2016 1. INTRODUCTION CapitaLand Limited (the Company ) wishes to announce
More informationComing to America. U.S. Tax Planning for Foreign-Owned U.S. Operations
Coming to America U.S. Tax Planning for Foreign-Owned U.S. Operations September 2015 Table of Contents Introduction... 2 Tax Checklist for Foreign-Owned U.S. Operations... 2 Typical Life Cycle of Foreign-Owned
More information(1) MAJOR AND CONNECTED TRANSACTION PROPOSED DISPOSAL AND (2) NOTICE OF BOARD MEETING FOR POSSIBLE DECLARATION OF A SPECIAL INTERIM DIVIDEND
Hong Kong Exchanges and Clearing Limited and The Stock Exchange of Hong Kong Limited take no responsibility for the contents of this announcement, make no representation as to its accuracy or completeness
More informationKingsoft Corporation Limited 金 山 軟 件 有 限 公 司
Hong Kong Exchanges and Clearing Limited and The Stock Exchange of Hong Kong Limited take no responsibility for the contents of this announcement, make no representation as to its accuracy or completeness
More information2003 ISDA. Credit Derivatives. Definitions ISDA INTERNATIONAL SWAPS AND DERIVATIVES ASSOCIATION, INC.
2003 ISDA Credit Derivatives Definitions ISDA INTERNATIONAL SWAPS AND DERIVATIVES ASSOCIATION, INC. Copyright 2003 by INTERNATIONAL SWAPS AND DERIVATIVES ASSOCIATION, INC. 360 Madison Avenue, 16 th Floor
More informationShareholder Dividend Reinvestment and Stock Purchase Plan
Shareholder Dividend Reinvestment and Stock Purchase Plan 2012 Offering circular 1 WHAT S INSIDE Introduction 3 Summary 4 Contact Information 4 Questions and Answers 5 Shareholder Dividend Reinvestment
More informationCLIENT ATTORNEY PRIVILEGED WORK PRODUCT. Jurisdictional comparison The Netherlands Luxembourg Cyprus Holding companies
Jurisdictional comparison The Netherlands Luxembourg Cyprus Holding companies CORPORATE/LEGAL Incorporation time and costs Possible in 3 days app. EUR 2,500 Less than a week app. EUR 4,000 Up to 2 weeks
More informationBRITISH TRANSCO INTERNATIONAL FINANCE B.V. Rotterdam, The Netherlands. Annual Report for the year ended 32 March 2015
BRITISH TRANSCO INTERNATIONAL FINANCE B.V. Rotterdam, The Netherlands Annual Report for the year ended 32 March 215 ADDRESS: Westblaak 89 312 KG Rotterdam Chamber of Commerce Rotterdam File number: 24,262.646
More informationHolding companies in Ireland
Holding companies in Irel David Lawless Paul Moloney Dillon Eustace, Dublin Irel has long been a destination of choice for holding companies because of its low corporation tax rate of 12.5 percent, participation
More informationCOMPANY LAW OF MONGOLIA CHAPTER 1 GENERAL PROVISIONS
COMPANY LAW OF MONGOLIA CHAPTER 1 GENERAL PROVISIONS Article 1. Purpose of the Law 97.1. The purpose of this Law is to regulate the establishment, registration and reorganization of a company, its management
More informationShare redemption programme
Share redemption programme 2014 Information for shareholders in Sectra AB (publ) ahead of the Annual General Meeting on 8 September 2014 regarding the Board s proposal for a share split and mandatory redemption
More informationLuxembourg. Luxembourg Generally Accepted Accounting Principles (GAAP) and the Luxembourg Law dated December 8, 1994.
Luxembourg International Comparison of Insurance * May 2009 Luxembourg General Insurance Definition Definition of property and casualty insurance company A company operating in the following insurance
More informationNAS 09 NEPAL ACCOUNTING STANDARDS ON INCOME TAXES
NAS 09 NEPAL ACCOUNTING STANDARDS ON INCOME TAXES CONTENTS Paragraphs OBJECTIVE SCOPE 1-4 DEFINITIONS 5-11 Tax Base 7-11 RECOGNITION OF CURRENT TAX LIABILITIES AND CURRENT TAX ASSETS 12-14 RECOGNITION
More informationNOTES TO THE CONDENSED CONSOLIDATED FINANCIAL STATEMENTS. Actuarial Gains and Losses, Group Plans and Disclosures
08 TCL Multimedia Technology Holdings Limited INTERIM RESULTS NOTES TO THE CONDENSED CONSOLIDATED FINANCIAL STATEMENTS 1. Basis of preparation The Directors are responsible for the preparation of the Group
More informationDaily Income Fund Retail Class Shares ( Retail Shares )
Daily Income Fund Retail Class Shares ( Retail Shares ) Money Market Portfolio Ticker Symbol: DRTXX U.S. Treasury Portfolio No Ticker Symbol U.S. Government Portfolio Ticker Symbol: DREXX Municipal Portfolio
More informationStatement of Financial Accounting Standards No. 7. Consolidated Financial Statements
Statement of Financial Accounting Standards No. 7 Statement of Financial Accounting Standards No. 7 Consolidated Financial Statements 30 November 2004 Translated by Wei-heng Lin, Associate Professor (Chung
More informationCertain capitalized terms in this Premium Dividend and Dividend Reinvestment Plan have the meaning assigned to them under "Definitions" below.
Premium Dividend and Dividend Reinvestment Plan Certain capitalized terms in this Premium Dividend and Dividend Reinvestment Plan have the meaning assigned to them under "Definitions" below. Important
More informationAssurance and accounting A Guide to Financial Instruments for Private
june 2011 www.bdo.ca Assurance and accounting A Guide to Financial Instruments for Private Enterprises and Private Sector t-for-profit Organizations For many entities adopting the Accounting Standards
More informationIndian Accounting Standard (Ind AS) 32 Financial Instruments: Presentation
Indian Accounting Standard (Ind AS) 32 Financial Instruments: Presentation Contents Paragraphs Objective 2 3 Scope 4 10 Definitions 11 14 Presentation 15 50 Liabilities and equity 15 27 Puttable instruments
More informationGUIDE TO THE SURVEY FINANCIAL BALANCE STATISTICS
1(16) GUIDE TO THE SURVEY FINANCIAL BALANCE STATISTICS 1 GENERAL INFORMATION... 3 2 DEFINITION OF DATA... 3 2.1 Positions... 3 2.2... 3 2.3... 4 3 DEFINITION OF VARIABLES... 4 3.1 Financial assets... 4
More informationSale of Series A Preferred Stock Company XYZ
Sale of Series A Preferred Stock Company XYZ SUMMARY OF TERMS (17/03/2010) THIS TERM SHEET SUMMARIZES THE PRINCIPAL TERMS OF A PROPOSED PRIVATE PLACEMENT OF EQUITY SECURITIES IN XYZ (THE "COMPANY"). EXCEPTING
More informationGUIDE TO LISTING OF PIK NOTES ON THE CISE: PRIVATE EQUITY TRANSACTIONS IN THE CHANNEL ISLANDS
GUIDE TO LISTING OF PIK NOTES ON THE CISE: PRIVATE EQUITY TRANSACTIONS IN THE CHANNEL ISLANDS CONTENTS PREFACE 1 1. PIK Notes 2 2. CISE Listing 2 3. Appleby Securities (Channel Islands) Limited 2 APPENDIX
More informationONXEO NOTICE OF MEETING. Extraordinary and Ordinary General Meeting of Shareholders. of Wednesday, April 6, 2016
ONXEO Public Limited Liability Company with a Board of Directors with share capital of 10,138,020.75 Company headquarters: 49 Boulevard du Général Martial Valin - 75015 Paris, France Paris Trade and Companies
More informationGlobal Value Fund Limited A.B.N. 90 168 653 521. Appendix 4E - Preliminary Financial Report for the year ended 30 June 2015
A.B.N. 90 168 653 521 Appendix 4E - Preliminary Financial Report for the year ended 30 June 2015 Appendix 4E - Preliminary Financial Report For the year ended 30 June 2015 Preliminary Report This preliminary
More informationAPPENDIX IV-10 FORM HUD 1731 - PROSPECTUS GINNIE MAE I MORTGAGE-BACKED SECURITIES (CONSTRUCTION AND PERMANENT LOAN SECURITIES)
GINNIE MAE 5500.3, REV. 1 APPENDIX IV-10 FORM HUD 1731 - PROSPECTUS GINNIE MAE I MORTGAGE-BACKED SECURITIES (CONSTRUCTION AND PERMANENT LOAN SECURITIES) Applicability: Purpose: Prepared by: Prepared in:
More informationTax accounting services: Foreign currency tax accounting. October 2012
Tax accounting services: Foreign currency tax accounting October 2012 The globalization of commerce and capital markets has resulted in business, investment and capital formation transactions increasingly
More informationShip Finance International Limited 3 months NIBOR + 4.00% Senior Unsecured Bond Issue 2010/2014 ( the Bonds )
Term sheet written in connection with application of listing on Oslo ABM Date: 2.12 2010 Status indication Final ISIN: NO 001058883.3 Ship Finance International Limited 3 months NIBOR + 4.00% Senior Unsecured
More informationINFORMATION SHEET NO.54. Setting up a Limited Liability Company in Poland December 2008
INFORMATION SHEET NO.54 Setting up a Limited Liability Company in Poland December 2008 General The Commercial Companies Code (KSH) regulates all issues related to the establishment, activity and dissolution
More informationDKLAHOMA TAX COMMISSION
DKLAHOMA TAX COMMISSION TAx POLICY DIVISION DAWN CASH, DIRECTOR Q* f * \ %/ PHONE ( 405) 521-3133 FACSIMILE ( 405) 522-0063 Re: Our file number Dear This letter ruling is in response to your letter ruling
More informationWhat Are the Tax Reasons Favouring the United Kingdom as a Holding Company Location for International Groups?
UK CLIENT MEMORANDUM ENGLISH LAW UPDATES What Are the Tax Reasons Favouring the United Kingdom as a Holding Company Location May 13, 2014 AUTHOR Judith Harger Recent activity in the merger and M&A space
More informationFacts. For the attention of Mr Marius Kohl
For the attention of Mr Marius Kohl Adm.injstration des Contributions Directes Bureau d'imposition Societes VI 18, Rue du Fort Wedell L-2982 Luxembourg PrkcwatcrhouscCoopcrs Societc a rcsponsabilitc limitcc
More informationInvestment Objectives and Management
DISCLOSURE STATEMENT DESERET POOLED INCOME FUND The Corporation of the President of the Church of Jesus Christ of Latter-day Saints (the "Church") has created the Deseret Pooled Income Fund, (the "Fund")
More informationARCH CAPITAL ADVISORS
ARCH CAPITAL ADVISORS TERM SHEET Mezzanine Debt This term sheet does not constitute an offer and is solely for discussion purposes. This term sheet shall not be construed as creating any obligations on
More informationIncome in the Netherlands is categorised into boxes. The above table relates to Box 1 income.
Worldwide personal tax guide 2013 2014 The Netherlands Local information Tax Authority Website Tax Year Tax Return due date Is joint filing possible Are tax return extensions possible Belastingdienst www.belastingdienst.nl
More informationAppendix 1 to notice to convene the EGM proposed new Articles of Association (the complete proposals with track changes)
Appendix 1 to notice to convene the EGM proposed new Articles of Association (the complete proposals with track changes) ARTICLES OF ASSOCIATION of TORM A/S CVR no. 22460218 Article 1 Article 1 1.1. 1.1
More informationJiangchen International Holdings Limited (Incorporated in the Cayman Islands with limited liability) (stock code: 01069)
Hong Kong Exchanges and Clearing Limited and The Stock Exchange of Hong Kong Limited take no responsibility for the contents of this announcement, make no representation as to its accuracy or completeness
More information