Flanders... your fastest link to the European market

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Flanders... your fastest link to the European market 12-01 - 010121

Already a strong connection between Flanders and India and growing fast... Diamonds: Antwerp Acquisitions: Belgium in top 3 in Europe Direct flights: Brussels European Hub for Jet Airways 11-00 - 170147

Flanders Belgium : Your Gateway to Europe 8 reasons to choose for Flanders/Belgium: 1. Strategic Location in Europe 2. Excellent infrastructure & connectivity : market access 3. Ease of setting up a company 4. Multilingual, highly educated, productive & loyal labour force 5. Flexible customs regulations 6. Generous Tailored Incentives 7. Excellent Business Environment 8. High Quality of Life

N 1 : Strategic Location in Europe Unique location at European crossroads 60% of EU purchasing power lies within 600 km of Brussels (short delivery & travel times) Proximity to EU headquarters of major commercial & official organisations (lobby activities!) The port of Antwerp is Europe s n 2, its most centrally located one, and port of entry for thousands of products.

Belgium at the heart of Europe EU=EU-27 members Flanders offers logistics operations access to the largest one-day-market in Europe: main markets can be served within 24 hours 54 Mio consumers (12%) 750 km 500 km 250 km 6 Bn GDP (67%) 3,7 Bn GDP (42%) 1,5 Bn GDP (17%) 131 Mio consumers (29%) 236 Mio consumers (53%) Total EU population: 490 Mio Total EU GDP: 12.00 trillion Source: PricewaterhouseCoopers, Report 2004 11-00 - 170149

Brussels... Capital of Flanders, Capital of the European Union Home of the European Commission and NATO Multicultural, multilingual, multinational Where Europe s heart beats 10-98 - 010204

An ideal location Brussels... Capital of Flanders Major international and domestic banking sector More than 160 embassies Fast and frequent international air and train links Where Europe s heart beats 10-98 - 010205

N 2 : Excellent Infrastructure Very dense roadway network (all toll free) Very dense railroad & inland waterway network connected to Europe s most important markets. 4 international seaports : Antwerp, Ghent, Zeebrugge, Ostend Max. 2 hrs drive to int l airport : one of Europe s largest cargo terminals. State-of-the-art ICT network (broadband,.)

Great Britain London Netherlands Amsterdam Chunnel Calais Provincial Capital Motorways Main Roads TGV Airports Harbors Lille Bruges Antwerp Hasselt Ghent Brussels Tournai Liège Mons Namur Paris Germany Bonn Frankfurt France Arlon 08-99 - 020617

Servicing the European market Stockholm Oslo Helsinki Moscow Lisbon Madrid London Frankfurt Warsaw Prague road distance drive time flight time Berlin 774 7:05 1:20 Warsaw 1,328 14:52 2:00 London 309 4:45 1:05 Leeds 636 7:23 1:40 Madrid 1,604 14:45 2:30 Lisbon 2,231 20:19 2:50 Frankfurt 398 3:43 1:05 Oslo 948 17:23 1:55 Stockholm 1,506 15:59 2:10 Helsinki 1,671 28:27 2:40 Moscow 2,582 31:48 3:20 Prague 918 8:50 1:25 In km and hours:minutes 11-02 - 170107

Principal European distribution locations Ranked matrix - 2005 London Amsterdam Ranking Belgium 1 France Cologne 2 Netherlands 3 Czech Republic Brussels 4 Poland 5 Germany 6 Frankfurt Hungary 7 Italy Paris High-speed trains Travel Time8 Frequency Austria Brussels -London 1hrs 309 9/day UK 10 Brussels -Paris 1hr 25 28/day Ireland 11 Brussels -Cologne 2hrs 30 9/day Portugal 12 Brussels -Amsterdam 2hrs 39 5/day Russia 13 Sweden Brussels -Frankfurt 3hrs 45 14 3/day Spain 15 Source: www.b-rail.be, 2004 Source: Cushman&Wakefield Healey&Baker, European Distribution Report 03-04 - 020202 2006 03-04 - 170160

Principal European distribution locations Ranked matrix - 2008 Ranking Belgium 1 Netherlands 2 Hungary 3 Czech Republic 4 Poland 5 France 6 Austria 7 Germany 8 Slovakia 9 Italy 10 UK 11 Denmark 12 Romania 13 Lithuania 14 Portugal 15 Source: Cushman&Wakefield Healey&Baker, European Distribution Report 200 03-04 - 170160

Top - 10 European distribution locations Ranking: 2004-2008 Ranking 2004 2006 2008 1 Belgium Belgium Belgium 2 France France Netherlands 3 Germany Netherlands Hungary 4 Netherlands Czech Republic Czech Republic 5 Czech Republic Poland Poland 6 Poland Germany France 7 Austria Hungary Austria 8 Hungary Italy Germany 9 Italy Austria Slovakia 10 UK UK Italy Source: Cushman&Wakefield Healey&Baker, European Distribution Report 2008 03-04 - 170160

Reason n 3 : Ease of setting up a company No restrictions on non-belgians! Belgium features a liberal business environment. Belgium has an open economy and a pro-market government, turning the country into an attractive company base No special permission is needed to set-up a company To incorporate your company (all foreigners possible) : min. 2 shareholders, min. 2 directors Set up time has been reduced to a couple of days

Flanders at the center of three major cultures Anglo-Saxon Brussels Latin Germanic and Nordic 10-98 - 010108

Reason 4: The right people Highly skilled workforce High quality of education with over 25% pursuing continuing education following university Strong work ethic and commitment to quality, resulting in higher productivity than any other region in Europe Multilingual and open to different approaches and cultures due to being at the crossroads of Europe

Speakers Percentage of of foreign population languages fluent in foreign languages 70 3 foreign languages None One 2 foreign Two languages Three Four 1 foreign language 100 60 90 90 50 90 80 40 80 70 73 30 20 70 60 55 10 50 0 44 38-10 40-20 30 Belgium Germany Spain France Italy 20Netherlands UK -30 20 14 12-40 10 10 10 5-50 -600-70 Belgium Denmark Netherlands France Ireland All Belgians can speak at least one other language, if not many more Source: UPS Europe Source: Business OECD Monitor, 1994 (SFCG) 2002 10-98 04-02 - 030111 030109

Reason n 5 : Flexible im/export & customs regulations Flanders has a very long tradition of international trade and still is one of Europe s leading trade hubs 000505

Customs regulations System of customs warehouses : offers possibility to store non-eu goods free of customs duties, trade policy measures, VAT & other taxes (and this for an unlimited period). Network of public & private bonded warehouses. Simplified procedures for declaration & special rulings possible Flexible European transit system with tax suspension.

Reason n 6 : Innovative tax benefits Notional Interest Deduction DTA with Hong Kong Dividend withholding tax exemption Efficient ruling system Favorable holding regime Interesting financing location Patent income deduction

Notional interest deduction The notional interest deduction allows companies and Belgian branches of foreign companies to reduce their taxable base when making investments from their own resources. This makes it an outstanding tax measure, especially for capital-intensive companies, headquarters and treasury centers. The amount that can be deducted as notional interest from the taxable base equals the fictitious interest cost on the adjusted equity capital. The notional interest rate for tax year 2009 is 4.307% (even 4.807% for SME s).

Notional interest deduction : example Assets Group Financing 10,000 Liabilities Share capital 10,000 P & L account Before notional interest deduction With notional interest deduction Profit before tax 500 500 Notional interest deduction (4,3 %) / - 430 Taxable 500 70 Corporate tax (33.99 %) 169.95 23,79 Effective tax rate 33.99 % 4,75 %

Advantages of the DTA with Hong Kong Hong Kong investments into EU averagely face: 25 % WHT on dividends 15 % WHT on interest & royalties Hong Kong investments into EU via a Belgian holding face*: 0 % WHT on dividends 0 % WHT on interest 0-5 % WHT on royalties * Through a combination of the Belgian DTA`s and Belgian internal law

Domestic dividend withholding tax exemption The domestic dividend withholding tax exemption extends the EU Parent-Subsidiary Directive between the 27 EU-countries to all countries worldwide that have a double tax treaty with Belgium. Using Flanders as their holding location for investments in Europe allows corporate investors from treaty countries to repatriate European profits free of dividend withholding tax

Tax rulings All taxpayers may request an advance ruling under which the Service for Advance Decisions will confirm the applicability of the tax code to a particular situation or specific transaction that has not yet taken effect from a taxation point of view. A ruling relating to any tax matter can be applied for: transfer pricing; absence of permanent establishment; participation exemption; withholding taxes; depreciation; tax deductions; capital gains.

Reason n 7 : Excellent business environment Flanders long tradition of trade and industry 000501

Advantages in Belgium : Smooth incorporation EU harmonized scale for import duties Flexible set of EU rules applicable to importing & distribution of goods Tax treaties with foreign jurisdictions designed after OECD model: no withholding tax on dividends (new since 2007) Rulings possible on : transfer pricing, provisions, depreciations, financing, warehouses, etc

Reason n 8 : High Quality of Life Safe environment First-class healthcare standards High quality housing at affordable prices Excellent education system with many international schools Rich cultural heritage A culinary tradition Great art-de-vivre

BRUSSELS EUROPEAN UNION CAPITAL QUALITY OF LIFE THANK YOU! ANTWERP, SEAPORT 2nd largest harbor in Europe; diamond capital of the world WORLD s MOST FAMOUS BEER CONCENTRATION OF R&D IN NANO AND BIO