Note 1:Dividends paid to a nonresident company are generally subject to a 15% withholding tax, unless the rate is reduced under an applicable tax treaty. Dividends paid by an SPF or a 1929 holding company or paid to a qualifying EU parent company under the EU Parent-Subsidiary Directive are exempt from withholding tax. No withholding tax is levied on dividends distributed by a Luxembourg company to a parent company located in a treaty country if conditions similar to those in the Luxembourg participation exemption regime are satisfied. The requirements for the exemption are that the parent company (i) holds at least 10% of the company paying the dividends or a participation acquired for at least EUR 1.2 million; (ii) holds or commits to hold the shares for an uninterrupted period of at least one year; (iii) has a legal form similar to the one of the forms listed in the Luxembourg corporate income tax code; and (iv) is subject to a tax similar to the Luxembourg corporate income tax.

Note 2:Luxembourg does not levy withholding tax on interest. However, profit-sharing bonds and debt instruments with remuneration linked to issuer profits are taxed as dividends at a rate of 15%.

Note 3:Luxembourg does not levy withholding tax on royalties.