Nokia 2005 Annual Report Download - page 125

purposes, generally will constitute US source gain or loss. In the case of a US Holder that is an
individual, any capital gain generally will be subject to US federal income tax at preferential rates
in effect until December 31, 2008 if specified minimum holding periods are met. The deductibility
of capital losses is subject to significant limitations.
The deposit or withdrawal by a US Holder of shares in exchange for ADSs or of ADSs for shares
under the deposit agreement generally will not be subject to US federal income tax or Finnish
income tax.
The sale by a US Holder of the ADSs or the underlying shares, other than an individual that, by
reason of his residence in Finland for a period exceeding six months, is or becomes liable for
Finnish income tax according to the relevant provisions of Finnish tax law, generally will not be
subject to income tax in Finland, in accordance with Finnish tax law and the Treaty.
Finnish Capital Taxes
The Finnish capital tax regime was abolished in the beginning of 2006.
Finnish Transfer Tax
Transfers of shares will be, and transfers of ADSs may be, subject to the Finnish transfer tax only
when one of the parties to the transfer is subject to Finnish taxation under the Finnish Income
Tax Act by virtue of being a resident of Finland or a Finnish branch of a non-Finnish credit
institution. In case the Finnish Transfer Tax Act is applicable, transfer tax, however, would not be
payable on stock exchange transfers. Otherwise, the transfer tax would be payable at the rate of
1.6% of the transfer value of the security traded.
Finnish Inheritance and Gift Taxes
A transfer of an underlying share by gift or by reason of the death of a US Holder and the transfer
of an ADS are not subject to Finnish gift or inheritance tax provided that none of the deceased
person, the donor, the beneficiary of the deceased person or the recipient of the gift is resident in
Finland.
Non-Residents of the United States
Beneficial owners of ADSs that are not US Holders will not be subject to US federal income tax on
dividends received with respect to ADSs unless this dividend income is effectively connected with
the conduct of a trade or business within the United States. Similarly, non-US Holders generally
will not be subject to US federal income tax on the gain realized on the sale or other disposition of
ADSs, unless (a) the gain is effectively connected with the conduct of a trade or business in the
United States or (b) in the case of an individual, that individual is present in the United States for
183 days or more in the taxable year of the disposition and other conditions are met.
US Information Reporting and Backup Withholding
Dividend payments with respect to shares or ADSs and proceeds from the sale or other disposition
of shares or ADSs may be subject to information reporting to the Internal Revenue Service and
possible US backup withholding at the current rate of 28%. Backup withholding will not apply to a
Holder, however, if the Holder furnishes a correct taxpayer identification number or certificate of
foreign status and makes any other required certification or if it is a recipient otherwise exempt
from backup withholding (such as a corporation). Any US person required to establish its exempt
status generally must furnish a duly completed Internal Revenue Service Form W-9 (Request for
Taxpayer Identification Number and Certification). Non-US Holders generally are not subject to US
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