Additional information
Other Dutch taxes and duties
No registration tax, transfer tax, stamp duty or any other
similar documentary tax or duty will be payable in the
Netherlands in respect of or in connection with holding
ADSs and/or common and/or cumulative preferred
financing shares.
Dutch Taxation for Resident ADS and/or Common
Shareholders - Withholding Tax
The following discussion is intended only for the following
ADS and/or common and/or cumulative preferred financing
shareholders or investors:
individuals who are residents or deemed to be residents in
the Netherlands for tax purposes or who have opted to be
taxed as residents in the Netherlands, excluding
(i) individuals who invest in ADSs and/or common and/or
cumulative preferred financing shares that form part of
a substantial interest or a deemed substantial interest in
Ahold or (ii) individuals who are, or are deemed to be,
Ahold's employees, director or board members or
individuals who are, or are deemed to be, employees,
directors, board members of companies related to us
(the "Dutch Individuals"); and
corporate entities, which term includes associations
which are taxable as corporate entities, that are resident
or deemed to be resident in the Netherlands for tax
purposes, excluding corporate entities that are (i) not
subject to Dutch corporate income tax, (ii) exempt from
such corporate income tax, including but not limited to
pension funds (pensioenfondsen) as defined under
Dutch law or (iii) portfolio investment institutions
(beleggings-instellingen) as defined under Dutch law,
which are generally subject to corporate income tax at
a rate of 0 percent.
In case of private individuals holding a substantial interest
in the aforementioned sense, dividends and/or capital gains
would be subject to Dutch income tax at a rate of
25 percent. During the year 2007 only, a tax rate of
22 percent applies to any income from or with regard to the
shares up to an amount of EUR 250,000. In case of
corporate shareholders holding a substantial interest as a
portfolio investment and not as part of an enterprise, any
dividends or capital gains are subject to the regular Dutch
corporate income tax rate.
Individual and corporate income tax
Dutch individuals not engaged in an enterprise
A Dutch individual (i) who holds ADSs and/or common and/
or cumulative preferred financing shares that are not
attributable to an enterprise of which such Dutch individual
derives a share of the profit, whether as an entrepreneur
(ondernemer) or pursuant to a co-entitlement to the net
worth of such enterprise other than as an entrepreneur or
an ADS and/or shareholder, (ii) who is not performing other
activities (werkzaamheid) in respect of the ADSs and/or
common and/or cumulative preferred financing shares,
including but not limited to activities which are beyond the
scope of active portfolio investment activities, and (iii) who
does not have a substantial interest or a deemed substantial
interest in Ahold, generally is subject to income tax at a rate
of 30 percent on a deemed yield of 4 percent of the average
market value of the ADSs and/or common and/ or
cumulative preferred financing shares at the beginning and
the end of the year, insofar as that average exceeds the
general exemption (heffingvrij vermogen).
Dutch individuals engaged in an enterprise and
corporate entities
Any benefits derived or deemed to be derived from ADSs,
common and/or cumulative preferred financing shares,
including any capital gains realized on the disposal thereof,
that are attributable to an enterprise of which the resident
derives a share of the profit, whether as an entrepreneur
(ondernemer) or as a person who has a co-entitlement to the
net worth of such enterprise other than by way of shares and/
or ADSs, common and/or cumulative preferred financing
shares, generally are subject to income tax at progressive
rates. Any benefits derived or deemed derived from ADSs,
common and/or cumulative preferred financing shares
including any capital gains realized on the disposal thereof
that are held by a Dutch resident corporate entity, generally
are subject to corporate income tax unless the Dutch
participation exemption applies.
Withholding tax
Dividends distributed by Ahold are generally subject to
a withholding tax imposed by the Netherlands at a rate of
25 percent (or 15 percent as from January 1, 2007). See
"Dutch Taxation for Non-Resident ADSs, Common and/or
Preferred Shareholders - Withholding Tax" above for a
definition of "dividends distributed by Ahold" as used
herein. Dutch individuals and Dutch corporate entities
generally can credit the withholding tax against their Dutch
income tax or corporate income tax liability and generally are
entitled to a refund of dividend withholding tax insofar as the
withholding tax exceeds their aggregate income tax or
corporate income tax liability. In the case of certain holders
of ADSs, common and/or cumulative preferred financing
shares subject to Dutch corporate income tax and enjoying
the participation exemption, no withholding tax may need to
be withheld at all. According to an anti-dividend stripping
146 Ahold Annual Report 2006
