Investment Fund Analysis & Strategy

Belgian Tax on Savings Income – 19bis - PwC Fund LP > 10% / 25% Targets Debt-related assets Principles - Sale/redemption of shares or liquidation of undertakings for collective investment ("UCI") assets invested in debt-related assets exceed 10%/25% (shares acquired before 1 January 2018) · Aims only at capitalisation UCIS • . • Threshold: statutory or actual basis ("Asset Test"). Taxation: debt-related assets accumulated during the detention period (Belgian Taxable Income per Share - "BTIS”). Taxable basis: о Difference between the BTIS on the date of sale/redemption and on the date of acquisition. No BTIS calculated: Asset Test O No Asset Test feasible: taxation of the full CG. 30% WHT by the debtor on the qualifying debt-related investments. • Fund of funds: consideration of the indirect investments PE funds also in scope (shares acquired from 1 January 2018). 29

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