AIRBUS - 2019 Registration Document

REGISTRATION DOCUMENT 2018

General Description of the Company and its Share Capital  /   3.4 Dividends

- - the Non-Resident Holder is an individual and such holder or a connected person to such holder (“ verbonden persoon ”) has, directly or indirectly, a substantial interest (“ aanmerkelijk belang ”) or a deemed substantial interest in the Company which is not attributable to an enterprise; or - - the income or capital gain qualifies as income from miscellaneous activities (“ belastbaar resultaat uit overige werkzaamheden ”) in the Netherlands as defined in the Dutch Income Tax Act 2001 (“ Wet inkomstenbelasting 2001 ”), including without limitation, activities that exceed normal, active portfolio management ( normaal actief vermogensbeheer ). Generally, a Non-Resident Holder of Shares will not have a substantial interest in the Company’s share capital, unless the Non-Resident Holder, alone or together with certain related persons holds, jointly or severally directly or indirectly, Shares in the Company, or a right to acquire Shares in the Company representing 5% or more of the Company’s total issued and outstanding share capital or any class thereof. Generally, a deemed substantial interest exists if all or part of a substantial interest has been or is deemed to have been disposed of with application of a roll-over relief. Gift or Inheritance Taxes Dutch gift or inheritance taxes will not be levied on the occasion of the transfer of Shares by way of gift by, or on the death of, a Non-Resident Holder, unless the transfer is construed as an inheritance or gift made by or on behalf of, a person who, at the time of the gift or death, is or is deemed to be resident in the Netherlands for the purpose of the relevant provisions. Value Added Tax There is no Dutch value added tax payable by a holder of Shares in respect of dividends on the Shares or on the transfer of the Shares. Other Taxes and Duties There is no Dutch registration tax, stamp duty or any other similar tax or duty other than court fees payable in the Netherlands by a holder of Shares in respect of or in connection with the execution, delivery and/or enforcement by legal proceedings (including any foreign judgment in the courts of the Netherlands) with respect to the dividends on the Shares or on the transfer of the Shares. Residence A Non-Resident Holder will not become resident, or be deemed to be resident, in the Netherlands solely as a result of holding a Share or of the execution, performance, delivery and/or enforcement of rights in respect of the Shares.

Withholding Tax on Dividends In general, a dividend distributed by the Company in respect of Shares will be subject to Dutch withholding tax at a statutory rate of 15%. Dividends include dividends in cash or in kind, deemed and constructive dividends, repayment of paid-in capital not recognised as capital for Dutch dividend withholding tax purposes, and liquidation proceeds in excess of the average paid-in capital recognised as capital for Dutch dividend withholding tax purposes. Stock dividends paid out of the Company’s paid-in-share premium, recognised as capital for Dutch dividend withholding tax purposes, will not be subject to this withholding tax. A Non-Resident Holder of Shares can be eligible for a partial or complete exemption or refund of all or a portion of the above withholding tax pursuant to domestic rules or under a tax convention that is in effect between the Netherlands and the Non-Resident Holder’s country of residence for tax purposes. The Netherlands has concluded such conventions with the US, Canada, Switzerland, Japan, almost all European Union Member States and other countries. Payments on the sale or other dispositions of Shares will not be subject to Dutch withholding tax, unless the sale or other disposition is, or is deemed to be, made to the Company or a direct or indirect subsidiary of the Company. In principle, a redemption or sale to the Company or a direct or indirect subsidiary of the Company will be deemed to be a dividend and will be subject to the rules set forth in “Withholding Tax on Dividends” above. Taxes on Income and Capital Gains A Non-Resident Holder who receives dividends distributed by the Company on Shares or who realises a capital gain derived from Shares, will not be subject to Dutch taxation on income or a capital gain unless: - - the income or capital gain is attributable to an enterprise or part thereof which is either effectively managed in the Netherlands or carried on through a permanent establishment (“ vaste inrichting ”) or permanent representative (“ vaste vertegenwoordiger ”) taxable in the Netherlands and the holder of Shares derives profits from such enterprise (other than by way of the holding of securities); or - - the Non-Resident Holder is an entity and has, directly or indirectly, a substantial interest (“ aanmerkelijk belang ”) or a deemed substantial interest in the Company and such interest is held by the Non-Resident Holder with the main purpose of or one of the main purposes of avoiding personal income tax for another person; or Withholding Tax on Sale or Other Dispositions of Shares

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Airbus / Registration Document 2018