Given the Hermès International opening share price on December 17, 2014 of 280.10 euros, the amount of the exceptional distribution in kind according to a ratio of two (2) Hermès shares for forty-one (41) LVMH Moët Hennessy Louis Vuitton shares, voted for by the Combined Shareholders’ Meeting held on November 25, 2014, is 13,66 euros per LVMH share.
This amount includes, per LVMH share:
- a portion amounting to 12.08 euros which qualifies as distributed income for tax purposes, corresponding to the Hermès share price limit cited in the communiqué dated November 25, 2014, taking the distribution ratio into account; and
- a portion amounting to 1,58 euros which qualifies as a repayment of capital for tax purposes, for the remaining amount.
With regard to tax treatment, shareholders are invited to refer to Part 3 of the communiqué published on November 3, 2014, and more specifically to Section 22.214.171.124 for the portion qualifying as a repayment of paid-in capital for individuals whose tax residence is in France.
For tax residents of France, the tax basis of the Hermès shares received through the distribution is the Hermès opening share price on this date, December 17, 2014 of 280.10 euros.
The exceptional distribution in kind will result in a reduction of 7 055 million euros in the Group share of LVMH’s consolidated equity and the recognition, in the consolidated financial statements as of December 31, 2014, of an exceptional capital gain of 2 810 million euros net of tax.
This document is a free translation into English of the original French “Distribution exceptionnelle d’actions Hermès International”. It is not a binding document. In the event of a conflict ininterpretation, reference should be made to the French version, which is the authentic text.