PF Finans / Clarinova

Taxation The following is a summary of certain Swedish tax consequences that may arise from the holding of the listed Bonds. The summary is based on Swedish tax legislation as currently in effect and is intended only as general information for Holders who are resident in Sweden for tax purposes, unless otherwise indicated. The summary does not deal comprehensively with all tax consequences that may occur in this context, nor does it cover the specific rules which may apply when Bonds are held by a partnership or are held as current assets in a business operation. Special tax consequences that are not described below may also apply for certain categories of taxpayers, including investment companies and mutual funds. Each Bond Holder is recommended to consult a tax advisor for information with respect to the tax consequences that may arise based on the Holder’s particular situation, including the applicability and effect of foreign tax legislation, provisions in tax treaties for the avoidance of double taxation and other rules which may be applicable. Capital income, such as interest on the Bonds and capital gains on the sale of Bonds, is generally taxed as income from capital at a flat rate of 30 per cent. A capital gain is taxable at the time of a binding agreement. Interest is generally taxable at the time the Holder can dispose of the interest. A preliminary tax at a flat rate of 30 per cent is withheld in respect of interest paid in cash on Bonds held in a VPC account or by a Swedish nominee. The withholding is made by Euroclear or, for nominee- registered securities, by the nominee. In some cases, preliminary tax is also withheld on payments of compensation for unpaid interest (e.g., when Bonds are redeemed). The capital gain or capital loss resulting from a sale or redemption of Bonds is calculated as the difference between the sales proceeds, after deduction for sales expenses, and the acquisition cost. The acquisition cost for all receivables of the same type and class is determined collectively in accordance with the “average method”. Compensation for interest that is accrued but not due (interest compensation) which is received on the disposal of a receivable is usually not taken into account when calculating a capital gain or capital loss. Such interest compensation is instead taxed separately as interest, in the fiscal year in which it is received. For the purchaser, the interest compensation is treated as an interest expense, deductible at the earliest of the interest falling due or the receivable being sold. Paid interest compensation is deducted separately and is, accordingly, not included in the purchaser’s acquisition cost. As a general rule, 70 per cent of a capital loss is deductible against any other taxable income from capital. Capital losses on listed receivables are, however fully deductible in the income from capital category. Receivables admitted to trading on regulated markets, such as the Bonds being to list the Bonds on the Corporate Bond List at NASDAQ OMX Stockholm , should normally be considered as listed. If a deficit arises in the income from capital category, a reduction of the tax on income from employment and from business operations, as well as real estate tax and the municipal real estate fee, is allowed. The tax reduction amounts to 30 per cent of any deficit not exceeding SEK 100,000 and 21 per cent of any remaining deficit. Deficits may not be carried forward to a later fiscal year. Individuals

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