Swiss withholding tax applies in respect of interest payments to holders of the DDM Senior Secured Notes

Following a ruling by the Swiss Federal Tax Administration, payments of interest
under the DDM Treasury SEK 300 million Senior Secured Notes with ISIN
SE0005280831 (the “Notes”) are subject to Swiss withholding tax since the
refinancing executed in June 2015.
On 23 June 2015 certain amendments to the documentation in respect of the Notes
became effective following a written procedure. These included a pledge of the
shares in DDM Treasury, introduced in order to strengthen the holders’ security
package. DDM Group AG, a Swiss limited liability company, is the pledgor of the
shares in DDM Treasury.

The ruling by the Swiss Federal Tax Administration is in contrast to the advice
from Swiss legal counsel, that at the time confirmed that no Swiss withholding
tax would apply despite the newly introduced share pledge. However, the Swiss
Federal Tax Administration has recently ruled contrary to the prior advice given
to DDM Treasury and concluded that DDM is liable to deduct Swiss withholding tax
at a rate of 35% from interest payments on the Notes. This is applicable as of
23 June 2015 and DDM Treasury will pay the withholding tax for the period up to
and including 5 July 2015.

PwC in Switzerland has on DDM’s request provided advice relevant to the majority
of holders of the Notes. Further information is available on DDM’s website, ddm
-group.ch, under the tabs “Investors” > “Bond loan 2013” and “Swiss tax
withholding”.

In brief, holders resident or incorporated in most EU member states are entitled
to a refund of all or most of the tax withheld, subject to them fulfilling the
conditions for a refund of such tax based on applicable double tax treaties in
place.

Please note that the Swiss withholding tax is not applicable to interest
payments under the fixed rate subordinated notes due September 2016 with ISIN
SE0005424272, issued by DDM Treasury in September 2013 and which does not
benefit from any security.

Claiming a refund
Holders of Notes domiciled in Sweden or the United Kingdom are entitled to a
refund from the Swiss Federal Tax Administration of the full amount of tax
withheld, subject to them fulfilling certain conditions for refund. Holders
domiciled in Luxemburg are entitled to a refund resulting in an effective Swiss
tax rate of 10% (i.e. a treaty reduction of 25%), subject to them fulfilling
certain conditions for refund. It is expected that such holders will be entitled
to a corresponding tax credit in Luxembourg. Holders resident or incorporated in
other EU member states will be able to claim a refund of all or most of the tax
withheld, subject to them fulfilling the conditions for refund, and should
likely be entitled to tax credit in their home jurisdictions for any non
-refundable Swiss withholding taxes.

Next interest payment date
The annual interest rate for the Notes is 13% and the next interest payment date
is 5 January 2016. In accordance with the above, on such date a cash amount of
SEK 42,250 per SEK 1 million Note (equal to an annual interest rate of 8.45%)
will be paid out by DDM Treasury to the holders of the Notes. Since the terms
and conditions for the Notes do not contain any liability for DDM Treasury as
issuer to compensate the holders for any tax withholdings, the amount withheld
as Swiss tax will consequently have to be reclaimed from the Swiss Federal Tax
Administration by each holder of Notes, and to the extent it cannot be reclaimed
used as tax credit in the relevant holder’s home jurisdiction, as applicable.

DDM regrets the inconvenience this causes for the holders of the Notes.

The content of this press release should not be construed as financial or tax
advice. Investors need to seek advice to determine their own specific situation.
The above description only serves as a general guide according to DDM’s
understanding and should not be relied on as advice.
For more information, please visit DDM’s website at www.ddm-group.ch or contact:

Anders Antonsson, Investor Relations
Mail: investor@ddm-group.ch | Tel: 46 8 4080 9030
DDM Holding AG (Nasdaq First North Stockholm: DDM) is a multinational investor
and manager of distressed assets. Since 2007, the DDM group has built a
successful platform in Eastern Europe, with 2.2 million receivables in nominal
value over EUR 1.7 billion. DDM Treasury Sweden AB (publ) (NGM: DDM1) is a
subsidiary wholly owned by DDM Holding AG. Pareto Securities is DDM Holding AG’s
Certified Adviser.