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Investor Presentaiton

ETT/ORIP: German Extraterritorial Tax Regimes ETT/ORIP: 德国域外税收制度 Background 背景 ATA Extraterritorial Taxation ("ETT") and Offshore Receipts in regard to Intangible Property ("ORIP") is the name given to a tax levied by a jurisdiction that applies to transactions involving intangible property ("IP") where: • Neither direct party to the transaction is tax resident in that jurisdiction; Neither non-resident entity has a local permanent establishment, an avoided permanent establishment under domestic law, or any other physical presence; and • The transaction is not executed in that jurisdiction. This taxing right is typically exercised as a result of: (i) the IP being registered in that jurisdiction; and / or (ii) the IP being used or exploited in that jurisdiction. ETT and ORIP can be distinguished as follows: • "ETT" applying to transfers of intangibles "ORIP" applying to payments or accruals for the use of intangibles © 2021. For information, contact Deloitte China. 22
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