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Apropos dividend withholding tax on income pension funds, the exemption in withholding tax act for dividend distributions from Dutch companies to Dutch pension funds may have the effect of dissuading Dutch pension funds from investing in companies which have their seat in EU Member States, and may also constitute an obstacle for those companies raising funds in the Netherlands. A comparison with Exhibit 1 reveals that remitting profits as a current dividend results in an MTR equal to the host country's combined tax rate plus the dividend withholding tax rate, multiplied by the after-income-tax rate. Assuming effectiveness of the first step merger, the payment will be subject to a 15% Luxembourg dividend withholding tax, since the payment will be made by ArcelorMittal S. |
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