Dutch Companies as a Tax Planning Tool St.Petersburg, September 28th 2010 Henk Eikelboom Jaap Bos

Why a company in the Netherlands? The Netherlands have a: - Good economic and financial climate - Political Stability - High level of Infrastructure - Multilingual majority of employees, - up to date educated and well informed

Key factors of The Netherlands -Low jobless rate; low inflation and low interest rate; -Good banking system - Well organized system for monitoring and controlling financial markets and compliance through laws and regulations

Fiscal key factors (1) - Extensive tax treaty network with foreign countries (over 85!) -Upfront negociation with the tax authorities is possible (rulings) -Advantageous rules concerning intrests, dividends and royalty’s

Fiscal key factors (2) -Participation examption not only for dividends but also for currency gains an capitatal gains on shares(>5% ownership) -No taxes on capital -Carry back and carry over of losses

Witholding Tax for income from Dutch BV to a Russian companies Dividend5% (0% combination Dutch BV and Cyprus Ltd.) Interest0% Royalties0%

A Dutch B.V. (1) - BV = private company with limited liability - Set up by a Notary (make up of the articles) - Official permission of Ministery of Justice - Minimum share capital is euro

A Dutch B.V. (2) - Registered in the Chamber of Commerce - Located in The Netherlands for optimal tax advantages - Director can be another company

Organigram Russian company Cyprus Ltd. In any country One or more BO’s dividends loans interests Subsidiaries Dutch B.V.

Russian company Subsidiaries Russian company Dutch B.V. Subsidiaries Example loan INTRESTINTREST Loan from Russian Comp. to subsidiaries INTRESTINTREST INTRESTINTREST Witholding tax: 0% Witholding tax: 35%

Russian company Subsidiaries (EU country without treaty) Russian company Dutch B.V. Subsidiaries (EU country) Example dividend Dividend from subsidiaries in Argentina to Russian holding Witholding tax: 0% Witholding tax: 15% Cyprus Ltd Witholding tax: 0%

General remarks 1.We don’t sell structures, we advise you what is the best in your situation. 2.There are more possibilities by using f.e. Cyprus as a tax haven in combination with a Dutch B.V. 3.Think twice; tax playing is not a game.

What is Fundatio B.V.? 1.A small trust office in Netherlands with licence of the Dutch National Bank. 2.Member of a group of companies with tax advise, accounting and tax lawyers. 3.An international player with a network in Europe, East Africa and Curacao.

How can we serve you? 1.We offer management and registered office for fix prices; 2.We can advise you about international tax issues from The Netherlands; 3.We take care of your business in The Netherlands; one stop shopping issue

Fundatio B.V. Professional for professionals Rondweg 11d P.O Box AA WEZEP The Netherlands