The German Tax Agency (the BZSt) offers an electronic tax relief program (the DTV) designed to facilitate and accelerate German tax reclaims on equities by financial institutions. provides custodian banks with an electronic link to the BZSt via the System, allowing for streamlined and rapid processing of refund requests. System LLC supports charities and wishes to help them maximize their ability to undertake their charitable missions by waiving its normal fees and donating its tax relief services to charities. Issuer: Notice Date (No.): Security Type: ISIN / CUSIP: Issue Country: Record Date: Payment Date: Gross Dividend Amt: Default Tax Rate: Available Tax Rates: Services Available: Phase 1: DTV Phase 2: Long Form Reclaim: Porsche Automobil Holding SE May 27, 2014, 2014.06.008 Equity (including American Depositary Shares (ADRs)) ORD ISIN: DE000PAH0038 / CINS CUSIP: D6240C122 (ADR: 73328P106/US73328P1066) Germany May 27, 2014 (Only holdings as of the Record Date are entitled to tax refunds.) May 28, 2014 (ADR: 6/12/2014) 2.10 per share 26.375% 25%, 20%, 15%, 10%, 0% (depending on the domicile of the investor, see details below) DTV Quick Refund: See full details below. Long Form Reclaims: See full details below. Open: 5/27/2014 9:00 AM Cut off: Submissions accepted continuously, batches processed at the end of each week. Open: 11/29/2014 9:00 AM Cut off: 11/28/2014 8:00 PM End of calendar year 2018 1
How to Read this Important Notice: The information in this important notice is organized as follows Order Topic Location 1 Synopsis Page 2 2 DTV Quick Refund Features Page 3 3 Document Requirements Page 3 4 DTV Quick Refund Procedure / Steps: Page 4 5 Long Form Reclaims, Links and Contact Page 5 6 Annex A: German Treaty Reduced Tax Rates Page 6 7 Annex B: Assurance and Guaranty for DTV Quick Refund Page 7..... Synopsis: Under German law, dividends paid by German payors to a non German resident holder of German shares, (including ADRs), are subject to a 26.375% statutory withholding tax at source. The last domestic paying agent must apply the 26.375% withholding tax to the dividend payable. Therefore all holders of German equity securities will be paid net of this withholding on the payment date. Most non German resident holders of German equity securities are eligible for a reduced rate of tax based on tax treaties that are in force between the shareholder s country of residence and Germany, and the investor type. Some types of holders, like U.S. charities and pension funds are exempt of German withholding tax under the U.S. Germany Double Taxation Treaty. provides the DTV Quick Refund via the System, s secure on line submission platform. This eliminates unnecessary delays in compiling paper documents and results in the optimized and timely electronic filing of the reclaims with the German tax authority. Tax refund payments are wired directly to the cash account specified by the custodian bank. DTV Quick Refund submissions are collected immediately following the Record Date up until the DTV deadline (6 months after the Record Date) and submitted continuously to the BZSt. Long Form reclaims are accepted from the day after the DTV deadline up until to the end of the 4 th calendar year following the Payment Date. 2
DTV Quick Refund Features: EDS Elections and Refund Payments: 1 DTC EDS elections are not needed. There are no DTC fees or indemnities. 2 Refund payment wired directly to the account specified, in USD or EUR, as requested. 3 All refunds paid are final with no risk of future claw backs under the Assurance and Guaranty, see Annex B. DTV Audit* Support: 1 directly co ordinates all audits with the BZSt, including facilitating residency certifications, and collecting any additional documentation, as needed. All activities are closely co ordinated with the custodian bank to ensure smooth processing. 2 Certificates of Residence are not required at the time of submission of a DTV Quick Refund (except in the case of U.S. tax exempt investors). In the case of an audit by the BZSt for an IRS Form 6166, provides access to a free 6166 service where clients can apply on line at no cost to them. DTV Quick Refund Processing Fees: 1 5% of the refunded amount will be deducted from the refund payment as a processing fee. 2 No fees for charities. Tax relief for charities via DTV Quick Refund is free of charge. waives its normal fees and donates its tax relief services to charities. believes charities perform good works and wishes to support their charitable, philanthropic or educational missions by helping them to maximize their ability to undertake their charitable missions. Foreign tax withholding on charities is wrong to start with, and wants to right the wrong and restore to the charities the funds that are rightfully theirs. Document Requirements: Investor Types: Physical Persons, Legal Entities, Investment Companies, Partnerships, LLCs, Estates, Trusts, and Participant Owned Accounts Required Items Upfront On Audit* Format 1 Composite BO Declaration Generated by the System 2 Security Position Inquiry printout Showing RD Position. 3 Beneficial Owner Declaration Can be completed on line: www.acupay.com/bzstdeclarationform. 4 Certificate of Tax Residence Form 6166 for U.S. Residents provided free of charge by for audit purposes. 5 German tax voucher Certified by the last domestic paying agent. 6 Ownership Questionnaire For partnerships, trusts, estates and investment companies. Can be completed on line: www.acupay.com/bzstdocumentation and and * Please note that this list is for indicative purposes only. Document requirements change based on beneficial investor type and country of tax residence. * The German tax authority carries out two types of audits after the refunds have been granted: Automated Audit: For 1/100 beneficial holders per DTV Quick Refund submission, the German tax authority requests a signed entity specific BO declaration ( automated audit ) that may need to be accompanied by a "proof of authority" if signed by the 3
custodian bank (e.g. a client account agreement ). Manual Audit: The German tax authority may request additional documentation at their discretion like for instance Certificates of Tax Residence, German tax vouchers or Letters of Determination. Investor Types: U.S. Tax Exempt Investors 26.375% (Full) Refund: U.S. Charitable Entities (e.g., 501c3), U.S. Qualified Pension Funds (e.g., 501a, 401a) Required Items Upfront On Audit* Format 1 Composite BO Declaration Generated by the System 2 Security Position Inquiry printout Showing RD Position. 3 IRS Form 6166 4 Declaration for U.S. Pension Funds Can be completed on line: www.acupay.com/bzstdocpensionfunds. 5 Letter of Determination for U.S. Charities. 6 Beneficial Owner Declaration Can be completed on line: www.acupay.com/bzstdeclarationform. 7 German tax voucher Certified by the last domestic paying agent. 8 Ownership Questionnaire For partnerships, trusts, estates and investment companies. Can be completed on line: www.acupay.com/bzstdocumentation (for U.S. Qualified Pension Funds) (for U.S. Charities) and and and DTV Quick Refund Procedure / Steps: Custodian banks and financial intermediaries must be approved by the German tax agency to use the DTV tax relief procedure. DTV Approvals are valid across branches of the same firm around the world. Please check with the D team in London or New York to find out if your institution is already approved. o If you or your custodian bank of financial intermediary are not approved yet, it is easy! Just go to http://www.acupay.com/bzstdtvapplication, fill in the interactive form, sign it and send it to us. We will take it from there! Submission: custodian banks must enter tax relief requests along with the beneficial owner information into the System. At the end of the process the System will generate a Composite BO Declaration and provide a breakdown of any additional documentation which must be provided as part of your submission. The Composite BO Declaration must be signed by the custodian bank or financial intermediary upon submission of their requests. For each submission the custodian bank must provide a Security Position Report (SPR) printout showing the record date position at the clearing system(s) and/or upstream custodian for the relevant ISIN or CUSIP. The total amount shown on the SPR must be equal to, or more than, the amount of client BO holdings submitted for German tax refunds. The SPR printout should be sent via scanned PDF or fax, accompanied by the Composite BO Declaration (which also serves as a bar coded transmittal document). Once you have printed, signed and compiled all of the documentation that the system indicates as being necessary, you must transmit all documentation to for processing. 4
Long Form Reclaims: If for any reason a custodian bank has not filed for tax relief via the DTV Quick Refund procedure, can facilitate a Long Form Reclaim for up to the end of the 4 th calendar year following the Payment Date. Please contact for further details. Links and Contact: Online assistance: Home: www.acupay.com System Login: www.acupaysystem.com Email: dteam@acupay.com Telephone assistance: New York: +1 212 422 1222 London: +44 207 382 0340 Links to Document Wizards Beneficial Owner Declaration: www.acupay.com/bzstdeclarationform Ownership Questionnaire: www.acupay.com/bzstdocumentation Declaration for U.S. Pension Funds: www.acupay.com/bzstdocpensionfunds U.S. Certificate of Residence (Form 6166): www.ustaxcertificate.com or www.us6166.com DTV Application form: www.acupay.com/bzstdtvapplication 5
Annex A German Tax Treaty Countries and Treaty Rates Albania 15% Ireland 15% Portugal 15% Algeria 15% Israel 25% Republic of Kosovo 15% Argentina 15% Italy 15% Romania 15% Armenia 15% Ivory Coast 15% Russia 15% Australia 15% Jamaica 15% Serbia 15% Austria 15% Japan 15% Singapore 15% Azerbaijan 15% Kazakhstan 15% Slovakia 15% Bangladesh 15% Kenya 15% Slovenia 15% Belarus 15% Korea (R.O.K.) 15% South Africa 15% Belgium 15% Kuwait 15% Spain 15% Bolivia 10% Kyrgyzstan 15% Sri Lanka 15% Bosnia Herzegovina 15% Latvia 15% Sweden 15% Bulgaria 15% Liberia 15% Switzerland 15% Canada 15% Liechtenstein 25% Syria 20% China 10% Lithuania 15% Taiwan 15% Croatia 15% Luxembourg 15% Tajikistan 15% Cyprus 15% Macedonia 15% Thailand 20% Czech Republic 15% Malaysia 15% Trinidad & Tobago 20% Denmark 15% Malta 15% Tunisia 15% Ecuador 15% Mauritius 15% Turkey 15% Egypt 15% Mexico 15% Turkmenistan 15% Estonia 15% Moldova 15% Ukraine 10% Finland 15% Mongolia 20% United Arab Emirates 15% France 15% Montenegro 15% United Kingdom 15% Georgia 10% Morocco 15% United States 15% Ghana 15% Namibia 15% Uruguay 15% Greece 25% Netherlands 15% Uzbekistan 15% Hungary 15% New Zealand 15% Venezuela 15% Iceland 15% Norway 15% Vietnam 15% India 10% Pakistan 15% Zambia 15% Indonesia 15% Philippines 15% Zimbabwe 20% Iran 20% Poland 15% PLEASE NOTE: This table is a summary only. Special rules or documentation requirements may exist for investors of certain types and categories, in some nations. has abstracted the relevant German tax treaty and regulations in an easy to use wizard, which includes on line access to relevant forms: www.acupay.com/germanyinfo/ 6
Annex B Assurance and Guaranty for users of the Full Service Quick Refund hereby agrees to indemnify all entities registered to employ the DTV Quick Refund procedure (i.e. those parties with DTV Approval Codes issued by the BZSt) which employ the DTV Quick Refund procedure (each such entity, a DTV Quick Refund User ) for their use of the German DTV procedure and to hold them harmless against any loss, liability, action, suit, judgment, demand, damage, cost or expense, including claims for the payment or repayment of dividends, interest, penalties or the loss of the use of funds withheld or refunded with respect to any dividend payment or claim properly made without negligence, wilful deceit or bad faith on their part arising out of, or in connection with, the use of s DTV services through the Full Service DTV Channel. The DTV Quick Refund User shall be protected and shall incur no liability for or in respect of any action taken or omitted to be taken or thing suffered in reliance upon any notice, direction, consent, certificate, affidavit, statement, telex, facsimile or other paper or document reasonably believed, in good faith and without negligence, to be genuine and to have been presented, signed or sent by the BZSt,, or any beneficial owner clients of the DTV Quick Refund User. In case any action shall be brought against the DTV Quick Refund User in respect of which recovery may be sought from under the terms of the indemnification described in this paragraph, the DTV Quick Refund User shall promptly notify in writing at the following address System LLC, 30 Broad Street, 46 th Floor, New York, NY 10004, Attn: Management. In no case shall be liable under this indemnity with respect to any claim against the DTV Quick Refund User unless shall be so notified by the DTV Quick Refund User of the written assertion of a claim against the DTV Quick Refund User or of any other action commenced against the DTV Quick Refund User, promptly after the DTV Quick Refund User shall have received any such written assertion or notice of commencement of action. may participate at its own expense in the defense of any action, and if so elects, may assume the defense of any pending or threatened action against the DTV Quick Refund User in respect of which indemnification may be sought hereunder, in which case shall not thereafter be responsible for the subsequently incurred fees and disbursements of legal counsel for the DTV Quick Refund User under this paragraph so long as shall retain counsel reasonably satisfactory to the DTV Quick Refund User to defend such suit. ACUPAY SYSTEM LLC New York and London January 1, 2014 7