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Tax Consequences of the Spin-Off for Shareholders: Allocation of Tax Basis and Acquisition (Procurement) Costs

The Spin-Off of the shares in Osram Beteiligungen GmbH leads to tax consequences for the shareholders of Siemens AG. The relevant effects have been addressed by the Joint Spin-Off Report of the Managing Boards of Siemens AG and Osram Licht AG.

Reference is made to p. 84 sq. of the Report. Pursuant to p. 86-89 of the Report, the following allocation key should be applied for the allocation of the tax basis of the shares in Siemens AG or the tax relevant acquisition (procurement) costs:

For US tax residents

For Canadian tax residents