Following our Announcement A10025, dated 15 February 2010, effective. 1 March 2010

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1 Announcement Tax A10033 Bulgaria: Tax relief procedure for Bulgarian securities Following our Announcement A10025, dated 15 February 2010, effective 1 March 2010 final beneficial owners can use the procedure indicated below to apply to obtain relief from withholding tax on income payments made on Bulgarian securities that are eligible in Clearstream Banking. Applicable withholding tax rates The standard rates of withholding tax applicable on income paid on Bulgarian securities are as follows: 10% on interest; and 5% on dividends. Reduced rates of withholding tax are available as follows: On interest and dividend payments if the beneficial owner qualifies in accordance with a Double Taxation Treaty (DTT) between its country of residence and Bulgaria. The maximum rate of withholding tax is defined in the relevant DTT (see Appendix 1 on page 5 (debt securities) and Appendix 2 on page 7 (equities)). On dividend payments if the beneficial owner is a resident of a European Union (EU) or European Economic Area (EEA) Member State (see Appendix 3 on page 9) entitled to exemption under Bulgarian domestic law. Note: Beneficial owners who are Bulgarian residents are allowed to hold Bulgarian securities through Clearstream Banking, but are taxed at the maximum tax rates (quoted above) and no tax relief is available through Clearstream Banking (either at source or via standard refund). Application for relief at source For Bulgarian debt securities, the first interest payment of the calendar year is paid net of withholding tax and no relief at source based on DTT eligibility is possible. Relief at source can be obtained for the second payment of the calendar year which can be received with the applicable DTT rate per final beneficial owner for whom the required certification described below was submitted in order to recover tax withheld for the previous payment of the calendar year. For Bulgarian equities, relief at source is available on dividend payments for beneficial owners who are EU/EEA residents. As a consequence, documentation requirements and deadlines vary according to the type of security and the residence status of the beneficial owner. Debt securities For beneficial owners to benefit from a second payment relief at source on interest paid on Bulgarian debt securities, you must provide Clearstream Banking with the following documents: One-time Certificate for Bulgarian Withholding Tax Purposes (see Appendix 4 on page 10), completed and duly signed by you, that specifies, among other things, whether or not you are the sole beneficial owner of all the Bulgarian debt securities held in the account. Any changes to any details must be communicated in a new One-Time Certificate. A10033 (1)

2 Claim form (see Appendix 5 on page 13), completed by each beneficial owner in five copies (available at and remaining valid for all respective future payments made during the applicable calendar year. The requirements for this form vary according to security type, as follows: For government bonds, the Claim form must be completed per beneficial owner. For corporate, mortgage and municipal bonds, the Claim form must be completed per beneficial owner and per issuer. Power of Attorney (see Appendix 10 on page 24) must be provided once and remains valid until revoked if the customer or third party is completing the Claim form on behalf of the beneficial owner. List of Beneficial Owners - Bulgarian Securities (see Appendix 6 on page 19), indicating, per beneficial owner, the name and complete address, the applicable withholding tax rate, the ISIN or common code, the total holding of securities, the withholding tax rate amount (BGN) and the income payment net amount (BGN). Deadlines for the submission of documents One-time Certificate for Bulgarian Withholding Tax Purposes Claim form Power of Attorney List of Beneficial Owners - Bulgarian Securities Five business days after the first payment date for which tax relief is claimed by the customer. Five business days after the date of the first payment made (by the respective issuer, if applicable) in the respective year. Five business days after the first payment date, together with the Claim form. 10 business days before each of the following payment dates of the respective year. Equities For beneficial owners to benefit from relief at source on dividends paid on Bulgarian equities, you must provide Clearstream Banking with the following documents: One-time Certificate for Bulgarian Withholding Tax Purposes (see Appendix 4 on page 10), completed and duly signed by you, that specifies, among other things, whether or not you are the sole beneficial owner of all the Bulgarian equities held in the account. Any changes to any details must be communicated in a new One-Time Certificate. Certificate of Residence (see Appendix 7 on page 20), issued by the beneficial owner s tax authorities annually before the first dividend payment in that year. To be accepted by the Bulgarian Tax Authorities, the Certificate of Residence must be in English (or, if it is in another language, a Bulgarian translation is required), must contain information as per the example in Appendix 7 on page 20 and must cover the record date of the respective dividend payment. List of Beneficial Owners - Bulgarian Securities (see Appendix 6 on page 19), indicating, per beneficial owner, the name and complete address, the applicable withholding tax rate, the ISIN or common code, the total holding of securities, the withholding tax rate amount (in Bulgarian Lev - BGN) and the income payment net amount (BGN). Note: Residents of DTT countries that are not an EU/EEA Member States cannot apply for relief at source on dividends but may recover tax withheld at source through the standard refund procedure, as explained below. A10033 (2)

3 Deadlines for the submission of documents One-time Certificate for Bulgarian Withholding Tax Purposes Certificate of residence List of Beneficial Owners - Bulgarian Securities Five business days after the first record date. Five business days after the first record date in the respective year. Five business days after each record date. Application for standard refund A standard refund of withholding tax on income from Bulgarian debt securities and equities is available if relief at source has not been obtained by the eligible beneficial owner. Documentation requirements To apply for a standard refund of withholding tax on income from Bulgarian securities, the following documents must be submitted, per payment date, to Clearstream Banking: Claim form (see Appendix 5 on page 13), one per reclaim application for one single payment date, completed by each beneficial owner in five copies (available at Power of Attorney (see Appendix 10 on page 24), provided once and remaining valid until revoked if the customer or third party is completing the Claim form on behalf of the beneficial owner. Credit Advice (see Appendix 8 on page 21), specifying income payment details including the security type, gross amount of the payment, date of the payment and amount of tax withheld. A Credit Advice must be completed for each intermediary financial institution between the beneficial owner and Clearstream Banking. For example, if the only intermediary financial institution between Clearstream Banking and the beneficial owner of the dividend income is the Clearstream Banking customer himself, then both a Clearstream Banking Credit Advice and a Credit Advice issued by the customer are required. Letter of Request to Clearstream Banking for Reclaim of Bulgarian Withholding Tax (see Appendix 8 on page 21), completed by the customer and authorising Clearstream Banking to reclaim withholding tax from the Bulgarian Tax Authorities on behalf the beneficial owner. Statutory deadline for receipt of the reclaim documentation The statutory deadline for reclaiming withholding tax using the standard procedure is five years after the relevant income payment for which tax reclaim is to be made. The deadline by which Clearstream Banking must receive the documentation for a standard refund application is, at the latest, two months before the statutory deadline. All standard refund applications received after this deadline will be processed by Clearstream Banking on a best-efforts basis. However, in such cases, Clearstream Banking will apply an extra charge and accepts no responsibility for forms that have not reached the Bulgarian Tax Authorities by the date considered being the statute of limitations deadline. With respect to tax reclaims in general, customers are reminded that Clearstream Banking accepts no responsibility for their acceptance or non-acceptance by the tax authorities of the respective country. It is the customer s responsibility to determine any entitlement to a refund of tax withheld, to complete the forms required correctly and to calculate the amount due. When are refunds received? The estimated time for receiving a refund is two months from the date on which Clearstream Banking receives the certified documents, although this can vary depending on when the application is filed and the complexity of the information supplied in the reclaim form. A10033 (3)

4 Capital gains tax Capital gains from transactions in shares in public companies and tradable rights and units in collective investment schemes on the Stock Exchange are not taxable. Capital gains tax is levied on trades made on the over-the-counter (OTC) market (that is, listed securities, unlisted securities), on government securities and on trades in debt securities made on the Stock Exchange (that is, corporate, municipal and mortgage bonds and compensatory instruments). Capital gains tax is levied on the positive difference between the selling and purchase amounts of trades for the calendar year. Declaration, calculation and payments are the responsibilities exclusively of the final beneficial owner; no responsibility falls on Clearstream Banking. Consequently, no action will be taken by Clearstream Banking with regard to capital gains tax and Clearstream Banking will not provide any reporting to its local custodian. Further information For further information, please contact the Clearstream Banking Tax Help Desk on: Luxembourg Frankfurt Telephone: (0) Fax: (0) or Clearstream Banking Customer Service or your Relationship Officer. For more general information regarding our products and services, please visit Appendices Appendix 1. Debt securities - Double Taxation Treaties concluded by Bulgaria and currently in force Appendix 2. Equities - Double Taxation Treaties concluded by Bulgaria and currently in force Appendix 3. EU/EEA Member States Appendix 4. One-time Certificate for Bulgarian Withholding Tax Purposes Appendix 5. Claim form (for information purposes only) Appendix 6. List of Beneficial Owners - Bulgarian securities Appendix 7. Certificate of Residence - example Appendix 8. Credit Advice Appendix 9. Letter of Request to Clearstream Banking for Reclaim of Bulgarian Withholding Tax Appendix 10. Power of Attorney - example As a registered customer, subscribe to our free alerts service to receive immediate, daily and/or weekly notification of the latest customer publications on our web site. Unsubscribe at any time; we respect your privacy. A10033 (4)

5 Appendix 1. Debt securities - Double Taxation Treaties concluded by Bulgaria and currently in force Note: Clearstream Banking provides these rates for information purposes only and does not guarantee that this information is correct, complete and accurate. Clearstream Banking does not assume liability for any damages, direct or indirect, that may arise from the reliance on or the use of this information. The rate as prescribed in the Double Taxation Treaty (DTT) may differ depending on the status of the beneficial owner. Please refer to the actual DTT or your tax advisor for further information. Country Rate prescribed by the DTT - Interest (%) Tax refund available (%) Prescribed form for tax refund The standard rate of withholding tax on interest is 10% before any relief. Albania 10 0 N/A Algeria 10 0 N/A Armenia 10 0 N/A Austria 0 10 Claim form Azerbaijan 7 3 Claim form Belarus 10 0 N/A Belgium 10 0 N/A Canada 10 0 N/A China 10 0 N/A Croatia 5 10 Claim form Cyprus 7 3 Claim form Czech Republic 10 0 N/A Denmark 0 15 Claim form Egypt N/A Estonia 5 5 Claim form Finland 0 10 Claim form France 0 10 Claim form Georgia 10 0 N/A Germany 0 10 Claim form Greece 10 0 N/A Hungary 10 0 N/A India 15 0 N/A Indonesia 10 0 N/A Iran 5 5 Claim form Ireland 5 5 Claim form Israel 10 0 N/A Italy 0 10 Claim form Japan 10 0 N/A Jordan 10 0 N/A Kazakhstan 10 0 N/A Korea, North 10 0 N/A Korea, South 10 0 N/A Kuwait 5 5 Claim form Latvia 5 5 Claim form Lebanon 7 3 Claim form A10033 (5)

6 Country Rate prescribed by the DTT - Interest (%) Tax refund available (%) Prescribed form for tax refund Lithuania 10 0 N/A Luxembourg 10 0 N/A Macedonia 10 0 N/A Malta 0 10 Claim form Moldova 10 0 N/A Mongolia 10 0 N/A Morocco 10 0 N/A Netherlands 0 10 Claim form Norway 0 10 Claim form Poland 10 0 N/A Portugal 10 0 N/A Romania 15 0 N/A Russia 15 0 N/A Singapore 5 5 Claim form Slovak Republic 10 0 N/A Slovenia 5 5 Claim form South Africa 5 5 Claim form Spain 0 10 Claim form Sweden 0 10 Claim form Switzerland 10 0 N/A Syria 10 0 N/A Thailand 15 0 N/A Turkey 10 0 N/A Ukraine 10 0 N/A United Arab Emirates 2 8 Claim form United Kingdom 0 10 Claim form United States of America 10 0 N/A Uzbekistan 10 0 N/A Vietnam 10 0 N/A Yugoslavia a 10 0 N/A Zimbabwe 10 0 N/A a. This treaty remains applicable in relations between Serbia and Bulgaria. Application of the treaty with Montenegro has yet to be confirmed by Bulgaria. A10033 (6)

7 Appendix 2. Equities - Double Taxation Treaties concluded by Bulgaria and currently in force Note: Clearstream Banking provides these rates for information purposes only and does not guarantee that this information is correct, complete and accurate. Clearstream Banking does not assume liability for any damages, direct or indirect, that may arise from the reliance on or the use of this information.the rate as prescribed in the DTT assumes that the beneficial owner does not hold a substantial percentage of the share capital of the company paying the dividend. Different rates may apply for substantial holdings. Please refer to the actual DTT or your tax advisor for further information. Country Rate prescribed by the DTT - Dividends (%) Tax refund available (%) Prescribed form for tax refund The standard rate of withholding tax on dividends is 5% before any relief. Albania 15 0 N/A Algeria 10 0 N/A Armenia 10 0 N/A Austria 0 5 Claim form Azerbaijan 8 0 N/A Belarus 10 0 N/A Belgium 10 0 N/A Canada 15 0 N/A China 10 0 N/A Croatia 5 0 N/A Cyprus 10 0 N/A Czech Republic 10 0 N/A Denmark 15 0 N/A Egypt 10 0 N/A Estonia 5 0 N/A Finland 10 0 N/A France 15 0 N/A Georgia 10 0 N/A Germany 15 0 N/A Greece 10 0 N/A Hungary 10 0 N/A India 15 0 N/A Indonesia 15 0 N/A Iran N/A Ireland 10 0 N/A Israel 10 0 N/A Italy 10 0 N/A Japan 15 0 N/A Jordan 10 0 N/A Kazakhstan 10 0 N/A Korea, North 10 0 N/A Korea, South 10 0 N/A Kuwait 5 0 N/A Latvia 10 0 N/A A10033 (7)

8 Country Rate prescribed by the DTT - Dividends (%) Tax refund available (%) Prescribed form for tax refund Lebanon 5 0 N/A Lithuania 10 0 N/A Luxembourg 15 0 N/A Macedonia 15 0 N/A Malta 30 0 N/A Moldova 15 0 N/A Mongolia 10 0 N/A Morocco 10 0 N/A Netherlands 15 0 N/A Norway 15 0 N/A Poland 10 0 N/A Portugal 15 0 N/A Romania 15 0 N/A Russia 15 0 N/A Singapore 5 0 N/A Slovak Republic 10 0 N/A Slovenia 10 0 N/A South Africa 15 0 N/A Spain 15 0 N/A Sweden 10 0 N/A Switzerland 15 0 N/A Syria 10 0 N/A Thailand 10 0 N/A Turkey 15 0 N/A Ukraine 15 0 N/A United Arab Emirates 5 0 N/A United Kingdom 10 0 N/A United States of America 10 0 N/A Uzbekistan 10 0 N/A Vietnam 15 0 N/A Yugoslavia a 15 0 N/A Zimbabwe 20 0 N/A a. This treaty remains applicable in relations between Serbia and Bulgaria. Application of the treaty with Montenegro has yet to be confirmed by Bulgaria. A10033 (8)

9 Appendix 3. EU/EEA Member States The 32 member countries include the 27 European Union Member States together with Iceland, Liechtenstein, Norway, Switzerland and Turkey. Austria France Liechtenstein Romania Belgium Germany Lithuania Slovakia Bulgaria Greece Luxembourg Slovenia Cyprus Hungary Malta Spain Czech Republic Iceland Netherlands Sweden Denmark Ireland Norway Switzerland Estonia Italy Poland Turkey Finland Latvia Portugal United Kingdom A10033 (9)

10 Appendix 4. One-time Certificate for Bulgarian Withholding Tax Purposes [Customer s letterhead] A certificate must be provided once; it will be valid until revoked and will be used for all future payments. Clearstream Banking Attn: OTL - Tax Services Frankfurt Neue Börsenstrasse 1 D Frankfurt am Main Germany Account: (Clearstream Banking account number(s)) (the Account ) We, the undersigned customer of Clearstream Banking, may hold from time to time in our Account securities issued by issuers who are organised, resident or incorporated in Bulgaria (the Securities ). We hereby certify that [tick one box only and complete as appropriate]: OR 1. We are the sole beneficial owner of all Securities that we may hold from time to time in the Account. We are resident for tax purposes in (country of residence) and are entitled to the application of a reduced withholding tax rate with respect to interest paid on the Securities according to the Double Taxation Treaty (DTT) concluded between our country of residence and Bulgaria. We hereby undertake to provide Clearstream Banking with a new One-time Certificate and a List of Beneficial Owners if, on any record date, we hold any such securities on behalf of third-party beneficial owner(s). We acknowledge that, in order to receive interest payments at the reduced rate granted according to the treaty mentioned above, we must provide Clearstream Banking with an official Claim form, duly completed and signed, on an annual basis and, if applicable, per issuer of the Securities within the applicable deadlines. 2. We are the sole beneficial owner of all Securities that we may hold from time to time in the Account. We are resident for tax purposes in (country of residence) (an EU/EEA Member State) and are entitled, according to Bulgarian legislation, to the application of withholding tax at 0% with respect to dividend income paid on the Securities by Clearstream Banking. We hereby undertake to provide Clearstream Banking with a new One-time Certificate and a List of Beneficial Owners if, on any record date, we hold any such securities on behalf of any third-party beneficial owner(s). We acknowledge that, in order to receive dividend payments without application of withholding tax, we must provide Clearstream Banking, on an annual basis and within the applicable deadlines, with a valid Certificate of Residence. OR A10033 (10)

11 Appendix 4 (cont). One-time Certificate for Bulgarian Withholding Tax Purposes 3. We hold the Securities for several beneficial owners (including ourselves, when applicable) who are eligible for a reduced rate of withholding tax with respect to: interest paid on the Securities, according to the DTT concluded between the beneficial owners respective countries of residence and Bulgaria. We hereby undertake to provide Clearstream Banking with: on an annual basis and, if applicable, per issuer: a valid Claim form, duly completed and signed by each eligible beneficial owner (including ourselves, if applicable); and per relevant interest payment date: a List of Beneficial Owners. dividends paid on the Securities according to Bulgarian domestic law. We hereby undertake to provide Clearstream Banking with: on an annual basis: a Certificate of Residence per eligible beneficial owner (including ourselves, if applicable); and per relevant dividend payment date: a List of Beneficial Owners. We irrevocably authorise Clearstream Banking and its depository to submit this One-time Certificate or a copy hereof and any document submitted to Clearstream Banking to the competent authorities, including the Bulgarian Tax Authorities, in connection with any administrative or legal proceedings or official inquiries for which tax-related certificates are or would be relevant. We hereby accept full responsibility in the event of any claims made: i) for additional taxes, interest thereon or penalties levied by the competent authorities in connection with any payments made in reliance upon this One-time Certificate, the Claim form or Certificate of Residence and the eventual List of Beneficial Owners and therefore indemnify Clearstream Banking in respect of any penalties, taxes and interest thereon levied by the competent Bulgarian authorities; and ii) in respect of any other costs incurred in connection with any action taken in reliance upon the contents of this One-time Certificate, such as but not limited to any liability of Clearstream Banking to the withholding tax administrator based on Clearstream Banking s reliance upon the contents of this One-time Certificate. We understand that, in order to obtain either a reduced withholding tax rate or exemption from withholding tax on any interest or dividend payment with respect to the Securities, whether according to a treaty concluded with Bulgaria or according to domestic legislation, it may be necessary for Clearstream Banking to provide certain information to the Clearstream Banking depository in Bulgaria, the issuer of the Bulgarian Securities, the paying agent and/or the Bulgarian authorities. We understand that the Bulgarian authorities may forward the information received from us in connection with this procedure to the respective tax authorities of the countries of residence of the beneficial owners. We hereby undertake to notify Clearstream Banking promptly upon receipt of any information that would render any statement in this One-time Certificate, including any Claim form, Certificate of Residence or List of Beneficial Owners, untrue, incomplete or otherwise no longer applicable. A10033 (11)

12 Appendix 4 (cont). One-time Certificate for Bulgarian Withholding Tax Purposes For and on behalf of: Name of Clearstream Banking Customer: Address: Authorised signatures:. Authorised Signature Authorised Signature Name Name Title Title Place Date A10033 (12)

13 Appendix 5. Claim form Five copies are required. These are available from the web site of the Bulgarian Tax Authorities at The following copy for the claimant is provided for information purposes only.. 137, This claim is issued under Art. 137, para 1 of the Tax and Social Security Procedure Code to comply with the requirements of Art. 136 of the Tax and Social Security Procedure Code. :... :... ( ) (for official use only) 5-5 th copy for the claimant, year concerned C L A I M... FOR RELIEF UNDER THE TAX TREATY BETWEEN B U L G A R I A AND..... / : Name of the payer of the income:, : Address, residence or seat of company: / Identification number/unique Identification code):. PART. Particulars of the payer of the income in Bulgaria / ( ): Name/ title (if company or body of persons):, : Address of fiscal residence of the claimant: / : Identification number/unique Identification code:. PART. Particulars of the claimant ( )? (a)which is your country of residence? ( )...*?,. (b) Have you/did you visit/ed Bulgaria in...*? If so, give dates of arrival and departure. 1., : 1. To be completed if the claimant is an individual: ( ), /...*?,,. (c) Have you retained a specific place to stay at and/or have you used a fixed base in Bulgaria during any portion of the year...*? If so, give the address and the period for which it was retained or used. *, 1 A10033 (13)

14 Appendix 5 (cont). Claim form * Specify the year to which income is related, where indicated 2., : 2. To be completed if the claimant is a company or body of persons: ( ), /. (a) Country of registration/incorporation. ( ),? (b) Address and country of head office. ( ),. (c) Country where control and management is exercised. ( ) ( ) ( ) ( ). (d) Address(es) of any branch(es) or office(s) in Bulgaria. 3., (, ) 3. Specific requirements to the claimant, if any, in relation to the application of the Tax Treaty (to be completed only if the Tax Treaty provides for such requirements),, :, ; ;,. Describe the facts related to the application of a specific provision of the Tax Treaty, such as your interest in the company, paying the dividends; nature of your main business; type of shares to be alienated, etc.,,. Facts declared herewith should be proved. 2 A10033 (14)

15 Appendix 5 (cont). Claim form. PART. Declaration of the payer of the income in Bulgaria DESCRIPTION OF THE INCOME COMPUTATION OF THE EXEMPTION OR REFUND OF TAX No ( ) Type (nature) of income Number and date of contract / ( ) Date of accrual/payment (for individuals) ( ) Gross amount of the income (before taxation).. Bulgarian tax due under domestic law Amount of tax under Tax Treaty ( 5 6) Amount of relief claimed (column 5 column 6) : TOTAL: The undersigned, -. hereby declares that all data furnished are true. ( ) (name and capacity) : : : Date: Signature: Stamp: 3 A10033 (15)

16 Appendix 5 (cont). Claim form D E C L A R A T I O N of the beneficiary of the income, ( ) I, (full name) ( * ) (name of individual or representative* of the company or body of persons), : Hereby declare that: 1.. This form is completed on my own behalf. : On behalf of: (, ) (to be completed if the beneficiary is a company or body of persons) ( ) (name of company or body of person) 2. /, / -. I / the company or body of persons am / is the beneficial owner of the income mentioned above. 3. / /,,. I/the company or body of persons don t/doesn t have a permanent establishment or a fixed base situated in Bulgaria from which the income arises. 4.,. All particulars and data furnished in this form are true and correct.,. I am acquainted with the responsibility in case of declaring incorrect informatrion. : Signature: : Stamp:, ( ) Capacity of the person who completes the claim (if claim is made on behalf of a company or body of persons) : Date and place: *, * A document, certifying the power of representation should be enclosed. 4 A10033 (16)

17 Appendix 5 (cont). Claim form, C E R T I F I C A TE of the Tax Authority of the beneficiary s country of residence : The Tax Authority of:, certifies that ( ) (country) is a resident under the respective ( / ) (name of claimant) Tax Treaty of : for the following years: ( ) (country) (specify the years concerned),. and is subject to tax in that country in respect of income included in this claim. : Name and position: : Stamp: : Signature: : Address of Tax Authority: : Date: EXPLANATORY NOTES 5 (, ), : 1., ( ), 2.,, : ( ) ; ( ) ; ( ) ; ( ) ; ( ) ; ( ) ; ( ),,.,.,,..,.,,,.,.,,., ,. This form is to be completed in 5 copies by a foreign person (which includes an individual, a legal person or body of persons) who/which: 1. is a resident of a country which has concluded a Tax Treaty with Bulgaria, and 2. claims relief from Bulgarian tax in respect of the income accrued in or derived from Bulgaria, such as: (a) dividends; (b) interest; (c) royalties; (d) fees for technical services; (e) management fees; (f) directors fees; (g) capital gains, income from personal and professional services, etc. All particulars in this form are to be furnished where applicable in Bulgarian or English language, in block letters or in electronic format. All particulars should be filled in identical way in all copies. The declarations should be duly completed, signed and stamped. The Tax Authorities of the country of residence of the claimant should issue the certificate of residence under the meaning of the respective Tax Treaty, prior to the submission of the claim to the respective National Revenue Agency Territorial Directorate in Bulgaria. All four copies of the claim form (except for the copy for the foreign tax authority) should be submitted in the National Revenue Agency Territorial Directorate. After the registration of the claim in the respective National Revenue Agency Territorial Directorate, the copies for the payer of the income and for the claimant should be returned to the person submitting the claim. This form is available at every National Revenue Agency Territorial Directorate in Bulgaria, and on the website of the Bulgarian National Revenue Agency. 5 A10033 (17)

18 Appendix 5 (cont). Claim form How to fill in the Claim form Year concerned Wording of the Claim form For relief under the tax treaty between Bulgaria and Explanation / required information The year of the payment: to be completed by the beneficial owner. Country of residence: To be completed by the beneficial owner in the case of DTT relief; To be left blank in case of exemption for residents of EU/EEA Member States. Part I. Particulars of the payer of the income in Bulgaria To be left blank. Part II. Particulars of the claimant Name/title (if company or body of persons) Address of fiscal residence of the claimant Identification number/unique identification code To be completed by the beneficial owner. The number/code required is: (for individuals) the social security number or ID number; 1. To be completed if the claimant is an individual 2. To be completed if the claimant is a company or a body of persons 3. Specific requirements to the claimant, if any, in relation to the application of the Tax Treaty (for legal entities) VAT or registration number. To be completed by the beneficial owner. For example, if the beneficial owner is a resident of an EU/EEA Member State or if the beneficial owner is eligible for full exemption under the applicable DTT. Part III. Declaration of the payer of the income in Bulgaria To be left blank. Declaration of the beneficiary of the income Certificate of the Tax Authority of the beneficiary's country of residence To be completed and signed by the beneficial owner. To be completed and signed by the local tax authorities of the beneficial owner. U.S. resident beneficial owners can submit an IRS Form 6166 in place of the competent authority certification requested in this section of the Claim form. However, they are still required to submit the Claim form with all other details duly completed and signed. A10033 (18)

19 Appendix 6. List of Beneficial Owners - Bulgarian securities A10033 (19)

20 Appendix 7. Certificate of Residence - example Note: Depending on the tax authority issuing the certificate of residence, the wording in the certificate may differ. [Letterhead of the beneficial owner s tax authorities] Date: Insert date Attention: Dear Sir/Madam, We confirm that name of beneficial owner, Tax ID number tax id number is resident in beneficial owner s country of residence for the purpose of the Double Taxation Treaty between Bulgaria and beneficial owner s country of residence and that, to the best of our knowledge and information, the above information is correct. Accordingly, name of beneficial owner qualifies for benefit from the Double Taxation Treaty between Bulgaria and beneficial owner s country of residence. Yours faithfully, Tax authorities date and stamp A10033 (20)

21 Appendix 8. Credit Advice The credit advice contains information that is required when filing a reclaim with a tax credit. This may vary depending on the financial institution paying the beneficial owner. The credit advice must be sent, under the letterhead of the customer or of the customer s agent, to: Clearstream Operations Prague s.r.o., Križíkova 148/34, Prague 8, Czech Republic Note: The customer must include, with the credit advice, the respective Clearstream Banking account number. [Customer s or agent s letterhead] Name of beneficial owner: Full address: Security details: Issuer of the security: Record date: Name of the security: Ex-date: Security code (ISIN): Payment date: Nominal currency-amount or Number of shares: Dividend/Interest rate: Dividend/Interest details: Gross dividend/interest: Withholding tax rate: Tax amount: Currency: Net dividend/interest: (before FX conversion) FX conversion details: (omit if not applicable) To currency: Value date: Fee amount: either (fixed) or (= % of net dividend/interest) Due dividend/interest payment details: Due payment amount: Due payment date: (net minus fee) (dd/mm/yyyy). Authorised Signature Authorised Signature Name Name Title Title Place Date Company stamp: A10033 (21)

22 Appendix 9. Letter of Request to Clearstream Banking for Reclaim of Bulgarian Withholding Tax [Customer s letterhead] Clearstream Operations Prague s.r.o. Attn: OTR - Tax Reclaim Services Križíkova 148/ Prague 8 Czech Republic Account: (Clearstream Banking account number(s)) (the Account ) Dear Sir/Madam, We refer to the following interest / dividend payment on the following security: Type of security: Issuer of the security: Security code (ISIN or Common Code): Interest/dividend payment date: Our Clearstream Banking Account was credited with the above interest / dividend under deduction of the domestic Bulgarian withholding tax rate, on the following quantity of securities beneficially owned by the following beneficial owner: Name of beneficial owner: Residence of beneficial owner (full address): Quantity of securities: Total interest / dividend amount received, net of withholding tax: We hereby request that Clearstream Banking to forward our application to the Bulgarian Tax Authorities for a refund of BGN BGN of withholding tax, to which the beneficial owner is entitled by virtue of: the Double Taxation Treaty between Bulgaria and country of residence of the beneficial owner; or Bulgarian domestic law, as a resident of an EU/EEA country. A10033 (22)

23 Appendix 9 (cont). Letter of Request to Clearstream Banking for Reclaim of Bulgarian Withholding Tax Please credit the withholding tax refunded to the above Clearstream Banking Account, with reference, upon receipt from the Bulgarian Tax Authorities. For and on behalf of: Name of Clearstream Banking Customer: Address: Authorised signatures:. Authorised Signature Authorised Signature Name Name Title Title Place Date We attach any other documentation as required by Clearstream Banking. A10033 (23)

24 Appendix 10. Power of Attorney - example [Beneficial owner s letterhead] Date: Insert date I/We name of beneficial owner, the undersigned, of address or place of business of beneficial owner, make, constitute and appoint Clearstream Banking or the Clearstream Banking customer or the third party, of address or place of business of Clearstream Banking or of the Clearstream Banking customer or of the third party my (our) true and lawful attorney-in-fact in my (our) name, place and stead, on my (our) behalf and for my (our) use and benefit, to exercise or perform any act, power or duty, right or obligation whatsoever that I (we) now have or may subsequently acquire with respect to the reclaim of tax withheld on investment income in respect of debt and equity securities. The rights, powers and authority of attorney-in-fact granted shall commence and be in full force and effect immediately upon the execution of this instrument. Such rights, powers and authority shall remain in force and effect thereafter until revoked by me (us) in writing. Yours faithfully,. Authorised Signature Authorised Signature Name Name Title Title Place Date A10033 (24)

25 Announcement Tax A December 2010 Bulgaria: New eligibility criteria for tax relief on interest Effective 1 January 2011 Background final beneficial owners that are legal entities resident in a European Union (EU) Member State may apply for a 5% reduced tax rate on interest from Bulgarian debt securities. The reduced rate is available if the payer of the interest (which is a Bulgarian legal entity) and the beneficial owner are related parties (that is, one of the legal entities has, for at least two years, been in possession of 25% of the capital of the other legal entity). The Bulgarian Parliament published, in the State Gazette of 30 November 2010, amendments to the Corporate Tax Act. Of these amendments, the one that impacts our current tax procedure for Bulgarian securities is the addition of new eligibility criteria, based on Bulgarian domestic law, for tax relief on interest payments 1. As of 1 January 2011, a final beneficial owner may apply for the 5% tax rate on interest from Bulgarian debt securities, instead of the standard 10% tax rate, provided that the following criteria are met: The beneficial owner is a legal entity resident in an EU Member State (see Appendix 1 on page 2); and The beneficial owner and the payer of the interest (which is a Bulgarian legal entity) are related parties (as defined above). Impact on customers In principle, the tax certification required to obtain the reduced 5% tax rate should remain as it is currently. However, an additional document may be required as proof that the one legal entity has, for at least two years, been in possession of 25% of the capital of the other legal entity. Furthermore, the official Claim form, which is part of the current procedure, makes clear reference to tax relief based on the treaty between the beneficial owner s country of residence and Bulgaria, which treaty does not apply because the new eligibility criteria are based on Bulgarian domestic law. According to information received from our local custodian, the Bulgarian Tax Authorities have yet to officially confirm any written procedures in relation to tax certification required to obtain the 5% tax rate or, in particular, any requirement to provide the Claim form or any other special certification instead. Our custodian will officially request the Bulgarian Tax Authorities to provide official clarification on how to comply with the changes. We will keep you up to date with developments in this matter. Further information For further information, please contact the Clearstream Banking Tax Help Desk on: Luxembourg Frankfurt tax@clearstream.com tax@clearstream.com Telephone: (0) Fax: (0) or Clearstream Banking Customer Service or your Relationship Officer. For more general information regarding our products and services, please visit 1. The amendments include no change with regard to dividend payments. 3 December 2010 A10211 (1)

26 Appendix 1. European Union Member States The 27 European Union Member States are as follows: Austria Finland Latvia Romania Belgium France Lithuania Slovakia Bulgaria Germany Luxembourg Slovenia Cyprus Greece Malta Spain Czech Republic Hungary Netherlands Sweden Denmark Ireland Poland United Kingdom Estonia Italy Portugal As a registered customer, subscribe to our free alerts service to receive immediate, daily and/or weekly notification of the latest customer publications on our web site. Unsubscribe at any time; we respect your privacy. 3 December 2010 A10211 (2)