The exchange may constitute a taxable disposal of your Notes and a taxable acquisition of the bonds in your country of residence. This can give rise to capital gains tax, income tax, or withholding tax, even though you receive no cash.
Two further points apply specifically to this exchange:
• Latvian withholding tax may apply to the in-specie distribution itself.
• Additional withholding may apply under Luxembourg law, because Eleving Group is a Luxembourg company.
Neither the issuer nor Mintos makes any representation about tax consequences for individual investors, and neither will gross up for any taxes applied. You should seek independent tax advice on your own position.