341 Netherlands withholding tax upon redistribution of foreign dividends Corporate and individual income tax Residents of the Netherlands Non-residents of the Netherlands If a holder of Aegon common shares is a resident or deemed to be a resident of the Netherlands for Netherlands corporate income tax  purposes and is fully subject to Netherlands corporate income tax or is only subject to Netherlands corporate income tax in respect of  an enterprise to which Aegon common shares are attributable, income derived from Aegon common shares and gains realised upon the  redemption or disposal of Aegon common shares are generally taxable in the Netherlands (at up to a maximum rate of 25%) under the  Netherlands corporate income tax act 1969  (Wet op de vennootschapsbelasting 1969) . If an individual is a resident or deemed to be a resident of the Netherlands for Netherlands individual income tax purposes (including an  individual who has opted to be taxed as a resident of the Netherlands), income derived from Aegon common shares and gains realised  upon the redemption or disposal of Aegon common shares are taxable at the progressive rates (at up to a maximum rate of 52%) under  the Netherlands income tax act 2001  (Wet inkomstenbelasting 2001)  if: If neither condition (i) nor condition (ii) above applies to an individual that holds Aegon common shares, such individual must determine  taxable income with regard to Aegon common shares on the basis of a deemed return on income from savings and investments  (sparen  en beleggen) , rather than on the basis of income actually received or gains actually realised. This deemed return on income from savings  and investments has been fixed at a rate of 4% of the individual’s yield basis  (rendementsgrondslag)  at the beginning of the calendar  year, insofar as the individual’s yield basis exceeds a certain threshold. The individual’s yield basis is determined as the fair market value  of certain qualifying assets held by the holder of Aegon common shares less the fair market value of certain qualifying liabilities on  1 January. The fair market value of Aegon common shares will be included as an asset in the individual’s yield basis. The 4% deemed  return on income from savings and investments is taxed at a rate of 30%. If a person is neither a resident nor is deemed to be a resident of the Netherlands for Netherlands corporate or individual income tax  purposes (nor has opted to be taxed as a resident of the Netherlands for individual income tax purposes), such person is not subject to  Netherlands income tax in respect of income derived from Aegon common shares and gains realised upon the redemption or disposal of  Aegon common shares, except if: i.  the individual is an entrepreneur  (ondernemer)  and has an enterprise to which Aegon common shares are attributable or the  individual has, other than as a shareholder, a co-entitlement to the net worth of an enterprise  (medegerechtigde) , to which  enterprise Aegon common shares are attributable; or ii. such income or gains qualify as income from miscellaneous activities  (resultaat uit overige werkzaamheden) , which include but are  not limited to the performance of activities with respect to Aegon common shares that exceed regular, active portfolio management  (normaal, actief vermogensbeheer) . i.  the person is not an individual and (1) has an enterprise that is, in whole or in part, carried on through a permanent establishment  or a permanent representative in the Netherlands to which permanent establishment or a permanent representative Aegon  common shares are attributable, or (2) is (other than by way of securities) entitled to a share in the profits of an enterprise or  a co-entitlement to the net worth of an enterprise, which is effectively managed in the Netherlands and to which enterprise  Aegon common shares are attributable. This income and these gains are subject to Netherlands corporate income tax at up to  a maximum rate of 25%. ii. the person is an individual that (1) has an enterprise or an interest in an enterprise that is, in whole or in part, carried on through a  permanent establishment or a permanent representative in the Netherlands to which permanent establishment or permanent  representative Aegon common shares are attributable, or (2) realises income or gains with respect to Aegon common shares that  qualify as income from miscellaneous activities  (resultaat uit overige werkzaamheden)  in the Netherlands which includes activities  with respect to Aegon common shares that exceed regular, active portfolio management  (normaal, actief vermogensbeheer) , or (3) is  Aegon must transfer to the Dutch tax authorities all Netherlands dividend withholding tax it withholds on dividends it distributed with  respect to the Aegon common shares. Provided certain conditions are met, Aegon may apply a reduction with respect to the  withholding tax that it has to pay over to the Dutch tax authorities. This reduction can be applied if Aegon distributes dividends that  stem from dividends Aegon itself has received from certain qualifying non-Netherlands subsidiaries, provided these dividends received  by Aegon are exempt from Dutch corporate income tax and were subject to withholding tax of at least 5% upon distribution to Aegon.  The reduction is applied to the Netherlands dividend tax that Aegon must pay to the Netherlands tax authorities and not to the amount  of the Netherlands dividend tax that Aegon must withhold. The reduction is equal to the lesser of: i.  3% of the amount of the dividends distributed by Aegon that are subject to withholding tax; and ii. 3% of the gross amount of the dividends received during a certain period from the qualifying non-Netherlands subsidiaries.