Poland – the right location for intangible services centres

2 Poland – key factors of successful investment by intangible services centres High percentage of graduates in IT, engineering, economics, etc. High mobility of skilled workforce Competent Polish managers Excellent motivation of young Polish employees Beneficial geographical location Tax incentives Business environment in Poland

3 High percentage of graduates in IT, engineering, economics, etc. (1) Second highest number of students in Europe Multiple academic and scientific units in all major cities Numerous technical universities and scientific centers - recognized scientists with world-renowned achievements - highly qualified engineers, IT specialists and biotechnologists Many talented, hard working and ambitious graduates Good knowledge of foreign languages

4 Foreign investment success stories involving young well educated Polish graduates over 40 R&D centers: High percentage of graduates in IT, engineering, economics, etc. (2) ABB Kraków Bosh - Siemens Łódź CapGemini Polska Wrocław Delphi Automotive System Kraków Siemens Wrocław TRW Automotive Częstochowa IBM Kraków Motorola Kraków Ontrack Katowice Oracle Warszawa Philips Piła, Kętrzyn

5 High percentage of graduates in IT, engineering, economics, etc. (3) Polish IT students won prestigious international programming competition (Top - Coder and Google Jam) R&D centers located in cities considered to have the best educated young employees in Poland e.g. ABB Kraków, Siemens Wrocław, Microsoft Warszawa, etc.

6 High mobility of skilled workforce  Intangible service centers located in both academic and non - academic cities  Change in the mentality of young Polish people in favour of moving to a new place Example: TRW engineering centre employs 300 professionals in Częstochowa

7 Competent Polish managers Tendency to replace foreign managers by experienced and highly motivated Polish managers Example: - In the consulting business, a decrease in the number of foreign to Polish managers ratio from 90% to 40% within the last 10 years

8 Excellent motivation of young Polish employees According to statistical data, Poland is a country where people work the longest hours Polish employees are highly evaluated by foreign investors as very much success driven

9 Beneficial geographical location Advantageous time difference ahead of the US European business culture

10 Tax incentives Possibility to operate within Special Economic Zones and benefit from income tax exemption up to 50% of capital expenditure or labour costs Tax incentives for R&D centers –if a new R&D centre is established – 20% of sales revenues can be treated as additional tax deductible cost –if new technology is acquired – 150% of related expenditure can be treated as tax deductible cost (50% premium) –Technological innovation credit is available to purchase fixed assets related to R&D

11 Business environment in Poland – legal and tax requirements (1) limited liability company (spółka z ograniczoną odpowiedzialnością) as the most popular legal form of newly established entities –minimum share capital required for an Ltd – PLN 50,000 (approx. EUR 12,500) –actions necessary to establish a new Ltd  executing the articles of association in the form of a notary deed  opening a bank account in a bank operating in Poland  paying the contributions to cover the entire share capital into the Polish bank account of the company  appointing the Management Board of the company (this can be done in the same notary deed as the articles of association); if they are not Polish citizens, a work permit is required  registering with the National Court Register (KRS)  registering for statistical purposes with the Statistical Office (obtaining REGON number)  applying to the tax office for tax identification number (NIP) and registering for VAT purposes –minimum time required to establish an Ltd – 1 month –time necessary to perform all the actions, including tax registration – up to 3 months

12 Business environment in Poland (2) Corporate Income Tax –standard rate – 19%  applicable to all types of income, including capital gains –taxation of resident and non-resident entities  capital gains of foreign investors – generally exempt from tax in Poland under relevant Double Tax Treaties (with the exception of Real Estate)  application of Double Tax Treaties to specific transactions – typical tax issues (e.g. cross-border lease – withholding taxes, permanent establishment exposure) –thin capitalisation and transfer pricing restrictions in place –application of EU Directives with respect to taxation of interest, royalties and dividends Value Added Tax –EU harmonised system  implementation of EU VAT Directives (including VI Directive) as of 1 May 2004 –Standard rate of 22%, reduced rates of 7% and 0%