Tax Saving Structures

1. Tax Saving Structures

2. No withholding tax on outbound dividends MALTA COMPANY • Tax exemption on income • 0% withholding tax based on the PSD EU COMPANY • Capital gains tax protection based on several DTT’s including Denmark, Italy, Sweden, Germany, Czech Republic, Poland, Slovenia, Spain, Portugal, United Kingdom

3. No withholding tax on outbound dividends MALTA COMPANY • Tax exemption on income • 0% withholding tax based on the broad implementation of PSD LUXEMBOURG HOLDING COMPANY • Capital gains tax protection based on DTT

4. No withholding tax on outbound dividends MALTA COMPANY • Tax exemption on income • 0% withholding tax based on the broad implementation of PSD DUTCH HOLDING COMPANY • Capital gains tax protection based on DTT

5. No withholding tax on outbound dividends MALTA COMPANY • Licensing or financing activities • Profits subject to 0-6.25% effective tax GERMAN COMPANY • 0% withholding tax on interest and royalty payments based on DTT

6. MALTA COMPANY Interest Payment • 0-6.25% effective tax on passive interest income • No transfer pricing documentation Loan TREATY COUNTRY/ EU COUNTRY AFFILIATED DEBTOR • Reduction of WHT based on treaty • Exemption from WHT based on EU interest and royalty directive

7. MALTA COMPANY Royalty Payment • 0-6.25% effective tax on passive licensing income • No amortisation – IP contributed at nominal value License TREATY COUNTRY/ EU COUNTRY AFFILIATED DEBTOR • Reduction of WHT based on treaty • Exemption from WHT based on EU interest and royalty directive

8. No withholding tax on outbound dividends MALTA COMPANY • 0-5% net effective tax on trading profits Country A High tax country

9. FOREIGN SHAREHOLDER • No withholding tax on outbound dividends MALTA COMPANY • Refund on dividend distribution • Profits subject to net effective tax of 5% plus gaming tax based on turnover MALTA LICENSED GAMING COMPANY

10. SHAREHOLDER • No withholding tax on outbound dividends MALTA COMPANY • Refund on dividend distribution • Profits subject to net effective tax of 5% MALTA E-COMMERCE COMPANY

11. No withholding tax on outbound dividends CYPRUS COMPANY EFFECTIVELY MANAGED & CONTROLLED IN MALTA • Effective management and control in Malta • Company subject to tax on income arising and on income remitted to Malta only • Income not subject to tax in Cyprus

12. OFFSHORE COMPANY Loan Interest Payment MALTA COMPANY • 0-6.25% effective tax • No transfer pricing documentation • No withholding tax on interest payments Loan Interest Payment TREATY COUNTRY/ EU COUNTRY AFFILIATED DEBTOR • Reduction of withholding tax based on treaty • Exemption from WHT based on EU interest and royalty directive

13. OFFSHORE COMPANY License • Owner of IP Royalty Payment MALTA COMPANY • 0-6.25% effective tax • No transfer pricing documentation • No withholding tax on royalty payments Sub- License Royalty Payment TREATY COUNTRY/ EU COUNTRY AFFILIATED DEBTOR • Reduction of withholding tax based on treaty • Exemption from WHT based on EU interest and royalty directive

14. Tax transparent • Income attributable to the trust is not subject to tax in Malta • Look-through approach – income directly received by the beneficiary • Non-residents not subject to tax other than on income arising in Malta or the transfer of immovable property in Malta MALTA TRUST

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