Investor Presentaiton

ETT/ORIP: German Extraterritorial Tax Regimes ETT/ORIP: Overview Scenario IPCo owns IP relating to various territories. The IP is licensed to Principal in exchange for royalties. Principal uses the licensed IP to manufacture products that it sells to local markets through local distributors. ORIP (or income ETT) Applies to royalty payments from Principal to IPCo. ETT (or capital ETT) Applies to transfer of IP from IPCo to Principal (or any other Licence payments potentially taxable IPCO ☐ Principal Local distributor © 2021. For information, contact Deloitte China. IP (deemed) transfer). Disposal Licence potentially taxable IPCO --++--- IP Principal Local distributor Acquisition of IP by Principal 23

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