CLIENT ATTORNEY PRIVILEGED WORK PRODUCT. Jurisdictional comparison The Netherlands Luxembourg Cyprus Holding companies

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1 Jurisdictional comparison The Netherlands Luxembourg Cyprus Holding companies

2 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 app. EUR 2,000 Share capital BV (Besloten vennootschap met beperkte aansprakelijkheid - Dutch private limited liability company): no minimum share capital, no authorized capital in the articles of association, capital may be denominated in a currency other than Euro, nominal value of shares may be expressed in more than two digits behind the decimal point. NV (Naamloze vennootschap Dutch public limited liability company): minimum share capital of EUR 45,000. Coop (Coöperatie met uitgesloten aansprakelijkheid a Dutch cooperative ): no minimum contribution. Sarl (Société à responsabilité limitée - Luxembourg private limited liability company): EUR 12,500 minimum share capital, denomination of the shares is free. SA (Société Anonyme - Luxembourg public limited liability company): EUR 31,000 minimum share capital, denomination of the shares is free. SCA (Société en Commandite par Actions Luxembourg partnership limited by shares): EUR 31,000 minimum share capital, denomination of the shares is free. Ltd. (a Cyprus limited liability company): no minimum share capital, denomination of the shares is free. Registered office Must be maintained in the Netherlands. Must be maintained in Luxembourg. Must be maintained in Cyprus.

3 Shareholders/directors BV/NV: Minimum 1 shareholder/1director. Coop: minimum 2 members/1 director. Sarl: minimum 1 shareholder/1 manager. SCA: minimum 2 limited partners/1 general partner. SA: minimum 1 shareholder/3 directors. Minimum 1 shareholder/1 director plus company secretary. Shareholders liability Limited to contribution. Sarl/SA: Limited to contribution. Limited to contribution. SCA: limited partners limited to contribution, general partner unlimited. Reporting Mandatory filing of annual accounts including financial statements and a management board report. Mandatory filing of annual accounts. Annual accounts and annual return must be filed with Registrar of Companies. Accounting requirements No mandatory audit, unless 2 of the following 3 criteria are fulfilled by the company during 2 successive years: - total assets exceeding EUR 4.4 million; - turnover exceeding EUR 8.8 million; - a workforce of more than 50 employees. No mandatory independent auditor, unless 2 of the following 3 criteria are fulfilled by the company during 2 successive years: - total balance sheet exceeding EUR million; - net turnover: exceeding EUR 6.25 million; - average number of full-time Mandatory audit annual accounts.

4 employees: 50. Confidentiality The companies register (reveals information concerning the directors, sole shareholder, registered address, incorporation date) and articles of association are publically accessible. The companies register (reveals information concerning the directors, shareholders and classes and amounts of shares held, registered address, incorporation date), articles of association are publically accessible. The companies register (reveals information concerning the directors, shareholders, registered address, incorporation date, charges and mortgages registered on company assets) is publically accessible. Meetings of shareholders May be held outside the Netherlands if the articles of association so provide or anywhere else if all shareholders agree and the managing/supervisory directors have been given the opportunity to advise on the proposed resolutions beforehand. May be held outside Luxembourg. Decisions can be also taken outside a physical meeting by way of a written resolutions of shareholders. May be held outside Cyprus. Decisions can be also taken outside a physical meeting by way of a written resolutions of shareholders/members. TAX Tax on capital contributions None. None. EUR 102 registration fee plus capital duty of 0.6% of the authorized capital and of any

5 subsequent increases in authorized capital (contributions with regards to merger or reorganization are exempt). Corporate Income tax rate 25% (20% for the first EUR 200,000 of profits). Effective combined rate of 29.22%. An annual minimum flat tax of EUR 3,210 is levied on holding companies of which the assets consist for more than 90% of financial assets. Such tax is creditable against a future tax liability. 10% (interest received other than in, or closely related to the ordinary course of business is subject to 15% special defense contribution ( SDC ) tax. Participation exemption regime Provides full exemption for both dividends and capital gains. Minimum participation of at least 5% and one of the following three tests is met: (i) (ii) The objective with respect to the participation is to obtain a return that is higher than a return that may be expected from regular asset management ( Purpose Test ); The direct and indirect assets of the subsidiary consist for Provides full exemption for both dividends and capital gains. 1-year holding period and minimum participation requirements apply. Minimum participation of at least 10% (or acquisition price of EUR 1.2 million for dividends and EUR 6 million for capital gains), participation is sufficiently taxed (i.e. a tax rate of 10.5% and a comparable tax base) and a minimum holding period of 12months applies. All dividends derived from a foreign participation are full exempt. No minimum participation or holding period requirements apply. SDC tax of 20% applies on dividends derived from a nonresident subsidiary that engages directly or indirectly for more than 50% in activities which lead to investment income and the foreign tax is significantly lower than the tax rate payable in Cyprus ( passive dividends ). Capital gains realized from the

6 less than 50% of so-called low-taxed free passive assets ( Asset Test ). Generally this Test is easily met by operating companies with an active business enterprise ; (iii) The subsidiary is subject to a genuine tax determined on Dutch tax standards (i.e. an effective tax of at least 10% according to Dutch tax standards) ( Subject-to-tax Test ). disposal of securities are exempt. Gains from sale of shares of unlisted companies owning immovable property in Cyprus are subject to 20% tax capital gains tax to the extent the gains are derived from such property. CFC, anti-abuse and interest deduction limitations Light CFC rules and certain limitations on the deduction of interest may apply (i.e. specially on the deduction of interest expenses on debt related to the acquisition of a participation). No CFC rules, but certain antiabuse provisions and limitations on interest deductibility may apply. No CFC rules, general antiavoidance provisions including the disregarding of artificial or factious transactions may apply. Dividend withholding tax ( WHT ) on outbound dividends (i) Domestic rate 15%. Subject to certain anti-abuse provision, the Dutch cooperative is fully exempt from withholding tax on distributions and is thus very efficient when dividend distributions are expected. 15%.

7 (ii) WHT on distributions made to EU corporate shareholders qualifying under the local implementation of the EU Parent/Subsidiary Directive 0% if a participation of at least 5% is held in the holding company. 0% if a participation of at least 10% (or EUR 1.2 million acquisition price) is held in the holding company for an uninterrupted period of at least 12 months. (iii) WHT on distributions made to corporate shareholders abroad the EU 15%, which may be reduced to 0% by means of an applicable tax treaty. Subject to certain anti-abuse provisions, the Dutch cooperative is fully exempt from withholding tax on distributions. 15%, which may be reduced to 0% by means of an applicable tax treaty. In addition, profit participating loans (i.e. CPECS) and partial redemption of shares are commonly used and taxefficient techniques to avoid withholding tax on distributions. No dividend withholding tax on overseas distributions to nonresidents. Withholding tax on interest payments 0% (an exception may apply for individuals by virtue of the EC Savings Directive). 0% on interest paid to nonresident recipients. Withholding tax on royalty payments None. None. None, unless the rights are used in Cyprus (subject to 10% withholding tax). Taxation of non-resident shareholders Capital gains and dividends may trigger Dutch taxes at the level of non-resident shareholders if a substantial interest is held in the holding company (i.e. Capital gains are only taxed in Luxembourg in case of the alienation of a substantial interest in the holding company (i.e. interest of more than 10%) and Capital gains and dividends derived by non-resident shareholders on the participation in the holding company are fully exempt from Cyprus tax at the

8 participation of at least 5%). Such taxation would not apply if the participation is attributable to a business enterprise at the level of the non-resident shareholder or such interest is not held with one of the main purposes to avoid Dutch personal income tax and/or Dutch dividend withholding tax liability at the level of another person. In practice, it is not difficult to show the presence of an enterprise at the level of nonresident shareholders. such gain is realized within a period of 6 months following the acquisition of the shares in the holding company. Dividends are not subject to Luxembourg taxes at the level of the non-resident shareholder. level of such shareholders. Tax rulings Advance tax rulings are granted confirming residency of the holding company and in relation to the participation exemption regime and the position of nonresident shareholders. Tax rulings are standard practice in Luxembourg and tax authorities are willing to issue tax rulings confirming the taxation of all matters that are of importance for a holding company (e.g. participation exemption regime, exemption of distributions in particular alphabetic shares and CPECS and also debt-financing activities). Although it is not standard practice, advance clearances are issued by the Cyprus tax authorities and are available upon request. Double Tax Treaty Network (i) Number of treaties in operation

9 (ii) Do any of the treaties include anti-treaties hopping provisions and/or detailed beneficial ownership tests? Yes, amongst others: NL-Portugal, NL-US, NL-Malta. Yes, amongst others, LUX-US. Yes, The Cyprus-US double tax treaty contains limitation of benefits provisions. Key items included in the tax treaty concluded with Russia Withholding tax rates (i) Dividends 5%: if the beneficial owner is a company other than a partnership) which holds 25% of the capital of the company paying the dividends and has invested at least EUR 75,000 (or the equivalent in other national currency). 15%: in all other cases. 10% (to be reduced to 5% under the New Protocol to the Treaty as per 2014): if the beneficial owner holds directly at least 20% of the company paying the dividends and has invested at least EUR 75,000 (or the equivalent in other national currency). 15%: in all other cases. 5%: if the beneficial owner has invested at least EUR 100,000 (or the equivalent in other national currency). 10%: in all other cases. (ii) Interest (iii) Royalties Local taxation of capital gains on shares (i) Local taxation of capital gains on shares No Russian local taxation (depending on local legislation this may be different for subsidiaries investing in No Russian local taxation (depending on local legislation this may be different for subsidiaries investing in No Russian local taxation, unless the local Russian subsidiary derives more than 50% of its value from immovable property

10 immovable property). immovable property). located in Russia). FEES Annual corporate fees of trust companies for management, administration and domiciliation service app. EUR 6,000 8,000. app. EUR 7,000 10,000. app. EUR Governmental fees None. Annual fee of app. EUR 135. Annual company maintenance fee EUR 350 payable to Registrar of Companies. DISCLAIMER No individual who is a member, partner, shareholder, employee or consultant of, in or to any constituent part of Van Campen Liem (whether or not such individual is described as a partner ) accepts or assumes responsibility, or has any liability, to any person in respect of this document. This document contains information confidential to Van Campen Liem. Copyright in the materials is owned by Van Campen Liem and the materials should not be copied or disclosed to any other person without the express authorisation of Van Campen Liem. This document is not intended to give legal advice and, accordingly, it should not be relied upon. It should not be regarded as a comprehensive statement of the law and practice in this area. Readers must take specific legal advice on any particular matter which concerns them. If you require any advice or information, please speak to your usual contact at Van Campen Liem.

11 CONTACT Marcello Distaso Yana Levin Netherlands J.J. Viottastraat JT Amsterdam The Netherlands T: E: Van Campen Liem is the joint trade name of Liem & Partners N.V. and Van Campen & Partners N.V. Liem & Partners N.V. has its statutory seat at Amsterdam, the Netherlands, and is registered with the Trade Register under number Van Campen & Partners N.V. has its statutory seat at Amsterdam, the Netherlands, and is registered with the Trade Register under number

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