Airbus - 2022 Universal Registration Document

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

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 inter alia dividends in cash or in kind, deemed and constructive dividends, (partial) repayments 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. As of 1 January 2024, a conditional withholding tax may apply against the highest corporate tax rate ( i.e. 25.8% in 2023) on dividends distributed by the Company to an affiliated ( gelieerde ) entity of it if such entity (i) is considered to be resident ( gevestigd ) in a jurisdiction that is listed in the annually updated Dutch Regulation on low-taxing states and non-cooperative jurisdictions for tax purposes ( Regeling laagbelastende staten en niet-coöperatieve rechtsgebieden voor belastingdoeleinden ), or (ii) has a permanent establishment located in such jurisdiction to which the interest is attributable, or (iii) is entitled to the interest payable for the main purpose or one of the main purposes to avoid taxation for another person, or (iv) is not considered to be the recipient of the interest in its jurisdiction of residence because such jurisdiction treats another (lower-tier) entity as the recipient of the interest (a hybrid mismatch), or (v) is not treated as resident anywhere (also a hybrid mismatch), or (vi) is a reverse hybrid whereby the jurisdiction of residence of a participant that has a qualifying interest ( kwalificerend belang ) in the reverse hybrid treats the reverse hybrid as tax transparent and that participant would have been taxable based on one (or more) of the items in (i)-(v) above had the interest been due to the participant directly, all within the meaning of the Withholding Tax Act 2021 ( Wet bronbelasting 2021). If the dividend withholding tax and the conditional dividend withholding tax as per 2024 will cumulate, the conditional dividend withholding tax will be reduced by the actual dividend withholding tax levied resulting in that the aggregate tax rate on dividends may rise from 15% to the highest corporate tax rate ( i.e. 25.8% in 2023). Conditional Withholding Tax on Dividends per 2024

Withholding Tax on Sale or Other Dispositions of Shares

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 – 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.

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Airbus / Universal Registration Document 2022