Investor Presentaiton

Overview of German Corporate Tax System AKU Tax rates are stable since 2008 2008*1#BÈ Corporate income tax (CIT) rate (CIT and trade tax (TT)) Participation exemption Net operating loss (NOL) carryforward Tax consolidation Controlled foreign company (CFC) rules Withholding tax (WHT) on dividends WHT on interest WHT on royalties Stamp duties Tax treaties Bookkeeping outside of Germany 15.825% CIT (including the solidarity surcharge) + the local trade tax, ranging from 7%-17% (average 14%) = average 30% rate 95% participation exemption for dividends (10%/15% minimum shareholding) and capital gains (no minimum shareholding) Indefinite (but subject to the change-in-ownership rules); annual utilization limited to EUR 1 million + 60% of the amount exceeding current-year profits Available where there is a parent-subsidiary relationship; a profit and loss pooling agreement (PLPA) is required Yes, but only with respect to low-taxed (<25%) passive income 26.375% - different rate might apply according to double tax treaty or EU directive Generally none 15.825% - different rate might apply according to double tax treaty or EU directive No Approx. 100 tax treaties (including China). There is currently no tax treaty with Hong Kong. Bookkeeping outside of Germany is only possible after formal approval by the German tax authorities © 2021. For information, contact Deloitte China. 12 12

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