Withholding Tax Clausole campione

Withholding Tax. All payments by the Issuer in the context of the holding, disposal or redemption of the Certificates, which are not profit sharing or do not have, in addition to a fixed interest, a variable interest depending on the profits distributed by the Issuer, can be made free and clear of any withholding or deduction for or on account of any taxes of whatsoever nature imposed, levied, withheld, or assessed by Luxembourg or any political subdivision or taxing authority thereof or therein, in accordance with applicable Luxembourg law, subject however to: (i) the application of the Luxembourg laws of 21 June 2005, as amended, implementing the Council Direc- tive 2003/48/EC (the "EU Savings Directive") and several agreements concluded with certain dependent or associated territories and providing for the possible application of a withholding tax of 35% on pay- ments of interest or similar income made or ascribed by a paying agent in Luxembourg (within the mean- ing of these laws) to or for the immediate benefit of certain non Luxembourg resident investors (individu- als and certain types of entities called “residual entities” within the meaning of article 4.2 of the EU Sav- ings Directive).The Luxembourg government however officially announced on 10 April 2013 its intention to give up the withholding tax system as from 1st January 2015 and apply the automatic exchange of in- formation system under the EU Savings Directive; (ii) the application as regards Luxembourg resident individuals of the Luxembourg law of 23 December 2005, as amended, which has introduced a 10% withholding tax (which is final when Luxembourg resi- dent individuals are acting in the context of the management of their private wealth) on savings income (i.e. with certain exemptions, savings income within the meaning of the Luxembourg laws of 21 June 2005, as amended, implementing the EU Savings Directive). Furthermore, pursuant to the law of 23 De- cember 2005, as amended, Luxembourg resident individuals can opt to self declare and pay a 10 per cent. tax on payments of interest or similar income made or ascribed by paying agents located in a Member State of the European Union other than Luxembourg, a Member State of the European Eco- nomic Area or in a State or territory which has concluded an agreement directly relating to the EU Sav- ings Directive on the taxation of savings income. Such 10 per cent. tax is final when Luxembourg resi- dent individuals are acting in the context of the management of...