18 April 2025
Notice to Non-Lithuanian Resident Noteholders Regarding Withholding Tax on Interest Payments of Notes due 7 May 2027 (ISIN LT0000409948) (hereinafter - the Notes)
The UAB BOX STORAGE Laisves 62 (hereinafter the Issuer), wishes to inform Noteholders who are not residents of Lithuania (natural persons) that additional information and clarification are available regarding the withholding of taxes on interest payments.
Reference is made to the Terms of the Notes Issue for the Issuance of Secured Notes up to EUR 2,500,000 with the Maturity till 7 May 2027 (hereinafter - the Terms). Terms used but not defined in this Notice (the “Notice”) have the same meaning as set out in, or incorporated by reference into, the Terms.
1. Personal Income Tax Reduction on Interest for Non-Lithuanian Resident Noteholders
As stated in the Taxes section of the Terms:
“According to the Article 5(4) and Article 6(1;12) of the Law on Personal Income tax (“Law on PIT”) interest payments made by the Issuer to identified non-resident Noteholders (natural persons) are subject to withholding personal income tax (“PIT”) at a rate of 15%.”
However, if a non-Lithuanian resident Noteholder wishes to lower the tax rate applicable to the interest income, they should provide to the Issuer one of the following documents:
- completed “Claim for reduction or exemption from the anticipatory tax withheld at source” (attached as Annex 1 and available here: https://www.vmi.lt/evmi/formos) (the “Signed and Completed Form FR0021 (DAS-1)”) by the Noteholder’s state of residence tax authority; OR
- if, according to the laws of the Noteholder’s state of residence, its tax authority does not complete and does not sign the Form FR0021 (DAS-1), then the Noteholder should provide:
- completed Sections I, II, III, and IV of the Form FR0021 (DAS-1) (the “Partially Completed Form FR0021 (DAS-1)”) by the Noteholder;
- and a tax residence certificate.
Once the above-mentioned sections of the form are completed and the required tax residence certificate is obtained, the original documents should be submitted to the Issuer at the following address:
UAB BOX STORAGE Laisves 62,Vilnius, Lvivo g. 25-701, LT-09320,
Lithuania
[email protected] Upon receipt of the above-described documents, the Issuer will be able to withhold the tax on interest at a reduced rate.
The Issuer notes that the original copy of the above-mentioned documents should be prepared, confirmed, and provided to the Issuer for each calendar year separately.
Considering that the next Interest Payment Date under the Notes is 30 April 2025, please be aware that the documents:
- Signed and Completed Form FR0021 (DAS-1)
- Partially Completed Form FR0021 (DAS-1) and tax residence certificate
have to be provided to the Issuer not later than 23 April 2025.
2. Refund Claim for PIT Withheld on Interest for Non-Lithuanian Resident Noteholders
In case the PIT has already been withheld at the source at the standard rate, i.e., if the Noteholder that is a Lithuanian tax non-resident individual did not complete the steps described above, it is possible to claim a tax refund by applying the lower PIT rate set in a respective Double Tax Treaty. The following documents are required:
- “Claim for refund of the tax withheld at source” (the "Form FR0022 (DAS-2)") should be submitted to the Lithuanian tax authority (attached as Annex 2 and available at: https://www.vmi.lt/evmi/formos); OR
- completed Sections I, II, III, and IV of Form FR0022 (DAS-2) (the "Partially Completed Form FR0022 (DAS-2)") together with a tax residence certificate.
Two copies of the form should be completed, i.e., one should be provided to the Lithuanian tax authority, and the other should remain for the records of the individual.
The PIT refund can be claimed for the current year and the five past calendar years.
The Issuer notes that the original copy of the above-mentioned documents should be prepared, confirmed, and provided to the Issuer for each calendar year separately.
Based on the information above, the following documents should be prepared:
- Two copies of either:
- Form FR0021 (DAS-2), or
- Partially Completed Form FR0022 (DAS-2) together with one exemplar of the required tax residence certificate;
- A copy of the individual’s identification document (passport or ID card);
- A cover letter indicating the individual's mailing address (for postal correspondence), addressed to:
Vilnius County State Tax Inspectorate
Ulonų str. 2
Vilnius, LT-01509
Lithuania
Once all documents are prepared, the complete package should be sent to the Issuer at the following address:
Merito Partners SIA
Roberta Hirša iela 1, Rīga, LV-1045.
Attn: Mikus Janvars
The decision regarding the PIT refund should be made, and the overpayment must be refunded within 30 calendar days after the completed Form FR0022 (DAS-2) is received by the Lithuanian tax authority.
Should any Noteholder have any queries about this Notice, please contact:
[email protected].
This Notice is issued and directed only to the Noteholders and no other person shall, or is entitled to rely or act on, or be able to rely or act on, its contents and should not be relied upon by any Noteholder for any other purpose.
Annexes:
- Claim for reduction or exemption from the anticipatory tax withheld at source (Form FR0021 (DAS-1))
- Claim for refund of the tax withheld at source (Form FR0022 (DAS-2))