PF Finans / Clarinova

Legal entities

Limited liability companies and other legal entities are normally taxed on all income, including capital gains and interest, as income from business operations at a flat rate of 26.3 per cent. As a general rule, capital losses on receivables, such as the Bonds, incurred by a corporate Holder are fully deductible against any taxable income from business activities. For the calculation of capital gains and losses, see section “Individuals” above. Compensation for unpaid interest should be treated as a taxable income for the seller and a tax deductible expense for the purchaser for the financial year to which it is attributable under generally accepted accounting principles. Deficits in a legal entity may be carried forward to a later fiscal year without any limitation in time.

Shareholders resident outside of Sweden

Generally, holders of receivables, such as the Bonds, who are not fiscally resident in Sweden and do not carry on business operations from a permanent establishment in Sweden are not subject to Swedish taxation in respect of a sale of such receivables. The same applies to interest income. These holders may, nevertheless, be subject to tax in their country of residence. There is no Swedish withholding tax on capital gains or interest paid on the Bonds.

Legal matters and supplementary information

The Company

The Company, Clarinova (company registration number 492065 ), was incorporated in Ireland as a private limited liability company on 30 November 2010 under the Companies Act,s 1963 to 2009. The Company has its registered office at Blair House, Upper O´Connell Street, Ennis, Co. Clare, Ireland

Material agreements

Material agreements outside the Company’s ordinary course of business Due to the nature of the Company’s business, and the contractual relationships created in the Company’s ordinary course of business, the Company has not, outside its ordinary course of business, entered into any agreements with a single counterparty or group of affiliated counterparties which may affect the Company’s ability to fulfil its obligations under the Bonds.

Litigation

The Company has not been and is not currently subject to any material court or administrative proceedings.

Permits

The Board of Directors considers that the Company holds the required permits regarding their activities.

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