AZERION GROUP N.V. (FORMERLY: EUROPEAN FINTECH IPO COMPANY 1 B.V.)

2022 Partner Footnotes

Azerion Group N.V. (formerly known as European FinTech IPO Company 1 B.V. or “EFIC1”) (the “Company”) may be considered a “passive foreign investment company” (“PFIC”) for U.S. federal income tax purposes, pursuant to which shareholders of the Company that are U.S. persons (each a “Shareholder”) could possibly make an election under Section 1295 of the U.S. Internal Revenue Code and the regulations thereunder to treat the Company as a Qualified Electing Fund (“QEF Election”) for U.S. federal income tax purposes. 

 

The Company is currently working on an analysis to determine its PFIC status, together with external tax and legal advisors. As of today, no assurance can be given as to the outcome of such analysis as PFIC rules are complex. Please refer to the 2021 Annual PFIC Statement for further information. The Company expects to provide further information on its 2022 PFIC status, a PFIC Annual Information Statement (where applicable) and appropriate documentation by August 2023 on the designated US Tax section of its investor website.

 

THE INFORMATION CONTAINED HEREIN DOES NOT CONSTITUTE TAX ADVICE. THE RULES DEALING WITH PFICS ARE VERY COMPLEX AND ARE IMPACTED BY VARIOUS FACTORS IN ADDITION TO THOSE DESCRIBED ABOVE. ALL SHAREHOLDERS ARE URGED TO CONSULT THEIR OWN TAX ADVISORS REGARDING THE CONSEQUENCES TO THEM OF THE PFIC RULES, INCLUDING, WITHOUT LIMITATION, WHETHER A QEF ELECTION, A MARK-TO-MARKET ELECTION OR ANY OTHER ELECTION IS AVAILABLE ON A TIMELY FILED OR AMENDED TAX RETURN AND THE CONSEQUENCES TO THEM OF ANY SUCH ELECTION AND THE IMPACT OF ANY PROPOSED OR FINAL PFIC TREASURY REGULATIONS