Germany: Reform Of The German Investment Tax Act (Investmentsteuergesetz) - June 2016

I. Executive Summary

On 9 June 2016 the German parliament (Bundestag) passed the German Investment Tax Reform Act. The Act still requires consent of the German Federal Council (Bundesrat) but it seems likely that such consent will be granted.

The German parliament (Bundestag) passed the German Investment Tax Reform Act without substantial changes compared to the Governmental draft of such act. In the last weeks the political discussion focused on the tax treatment of certain dealings around dividend exdate. Although this matter is only partly related to the reform of investment taxation an avoidance rule for such dealings was added to the German Investment Tax Reform Act.

The reform of investment taxation, i.e. the rules for taxation of investment funds, will enter into force as of 2018. In section II below we summarized the new tax system.

Certain material changes between the drafts of the German Investment Tax Act and the law that finally passed the German parliament (Bundestag) will be set forth in section III below. Please refer also to our prior client information dated 7 August 2015 and 7 January 2016.

Moreover, section V below covers amendments to the VAT treatment of Alternative Investment Funds ("AIF").

II. The New Investment Tax Law

The German Investment Tax Reform Act fundamentally changes the German investment taxation.

1. Scope

Generally, the Scope of the German Investment Tax Act covers investment funds as such term is defined in the German Capital Investment Code. However, there are certain important exceptions:

  • The most important would be that German and non-German partnerships (except for certain cases) no longer fall into the scope of the German Investment Tax Act. This means, that in particular, closed-ended fund organized as partnerships are exempted from the scope of the German Investment Tax Act. Such funds are subject to the general rules of taxation of partnerships, in particular the tax transparency of partnerships. Thus, the German tax treatment of such funds effectively remains the same as under current law.
  • In addition, participation companies pursuant to the German Participation Companies Act (Unternehmensbeteiligungsgesellschaften) and German REITs and non-German REITs that are subject to the provisions of the German REIT Act are not subject to investment taxation.

This means that only corporate type investment funds will fall into the scope of the German Investment Tax Act. However, it was explicitly stated that German and non-German investment funds of a contractual type (Sondervermögen) fall into the scope.

Moreover, certain entities may also fall into the scope of the German Investment Tax Act although they do not qualify as investment funds under the German Capital Investment Code, such as:

  • so-called single investor funds, i.e. investment undertakings that limit the number of investors to one single investor, but nevertheless satisfy all other requirements of an investment fund pursuant to the German Capital Investment Code;
  • companies that are prohibited from making active operations pursuant to the laws of its country of residence and that are not subject to or exempted from, income taxation.

The entities that fall into the scope of the investment tax act are legally defined as "investment funds". This may give rise to misunderstanding, particularly during the transition period, as the term "investment fund" is also used but having a different meaning under the law currently in force.

2. System of Investment Taxation

Under the reform of the investment taxation there are two tax regimes available for investment funds:

  • The base case is a newly introduced opaque tax regime where there are two levels of taxation: the investment fund and its investors. While this tax regime was designed for the needs of typical retail mutual funds it is, in fact, applicable to all investment funds that do not satisfy the specific criteria for specialized investment funds under the new law.
  • The tax regime for specialized investment funds is based on the tax regime for investment funds under the law currently in force (cf. §1 para1b of the German Investment Tax Act).

3. Taxation of Investment Funds

a) Level of Investment Fund

Only certain specific income from sources within Germany received by investment funds are subject to tax at the level of such investment funds, in particular income from German participations (dividends) and from real estate located in Germany.

While there was a provision on taxation of capital gains from shares of German companies in the first drafts of the German Investment Tax Reform Act such provision is no longer part of the final Act. Hence, such capital gains are not taxable at the level of the investment fund to the extent they are not attributable to a permanent establishment in Germany.

The full amount of income from German participations and from real estate located in Germany and certain other German source income is subject to German corporation tax at investment fund level. In particular, the exemption for (German) dividends (§8b of the German Corporation Tax Act) is not applicable at the level of the investment fund even if the relevant threshold (10%) is exceeded.

In addition, German trade tax may be triggered at the level of the investment funds if the fund is engaged in trade or business in Germany. However, an exemption is to be available if an entrepreneurial management of the investment fund's assets is excluded. The provisions dealing with German trade tax give rise to a number of questions.

b) Investor Level

At investor level there is a lump-sum taxation which is designed for the needs of retail mutual funds with a large number of investors.

The following items are subject to tax at investor level:

  • distributions;
  • pre-determined tax bases (Vorabpauschalen);
  • capital gains realized upon the dispositions or redemption of investment fund interests.

For individuals that hold their investment fund interests as part of their non-business assets such items are subject to flat income tax. For individuals that hold their investment fund interests as part of their business assets principally the full amount of such items is subject to income tax at their personal rate. For corporate investors the full amount of such items is subject to corporation tax. In addition, German trade tax may be triggered. The so-called partial income taxation and the exemption pursuant to §8b of the German Corporation Tax Act do not apply.

aa) Distributions and Redemptions

Under the new law repayments of capital shall qualify as taxable distributions. However, there is lack of a provision in the final Act on the deduction of the investor's acquisition cost during the liquidation process at latest. Thus, during the lifetime of an investment fund non-taxable repayments of capital may only be made by way of redemptions of investment fund interests.

ab) Pre-Determined Tax Base

The objective of the pre-determined tax base is to subject retained income of the investment fund.

The pre-determined tax base is based on the so-called base proceeds, a kind of minimum return which is determined on the base of the base interest rate pursuant to §203 para.1 of the German Valuation Act, i.e. possible long-term yield on public bonds. The base proceeds are capped at the actual increase in value of the investment fund. Moreover, the pre-determined tax base is equal to the difference between the base proceeds and the actual distributions.

The pre-determined tax base is deemed to be received by the investor in the immediately following calendar year. Hence, the possible dry income issues may be avoided (fully or partially) by a well-directed distribution policy.

ac) Partial Exemptions

Investment fund proceeds (i.e. distributions, pre-determined tax bases, capital gains from dispositions or redemptions) are subject to partial exemptions depending on the respective fund type:

  • with respect to equity funds (Aktienfonds) the partial exemption is as follows
    1. for individuals that hold their investment fund interests as part of their non-business assets 30% of such proceeds;
    2. for individuals that hold their investment fund interests as part of their business assets 60% of such proceeds;
    3. for corporate investors 80% of such proceeds.
    Equity funds (Aktienfonds) are investment funds that invest at least 51% of their value in equity participations. The term equity participations comprises of both listed equities and – other than first drafts – unlisted equities of companies that are subject to and not exempt from, a (minimum) taxation in its country of residence. Therefore, private equity funds may benefit from such partial exemptions.
  • With respect to so-called mixed funds (Mischfonds) half of the partial exemption rate applicable to equity funds (Aktienfonds) is available. Mixed funds are investment funds that invest at least 25% of their value in equity participations.
  • With respect to real estate funds – i.e. investment funds that invest at least 51% of their value in real estate and real estate companies – the partial exemption rate is 60% of the proceeds. If a real estate fund invests at least 51% of its value in non-German real estate and non-German real estate companies the partial exemption rate is 80% of the proceeds.

4. Specialized Investment Funds

The tax regime for specialized investment funds can be considered a continuation of the tax regime for investment funds under the law currently in force (§1 para.1b German Investment Tax Act).

To qualify as specialized investment fund an investment fund must satisfy certain criteria with respect to regulation, redemption rights, eligible assets and investment restrictions. These are substantially similar to the criteria under the law currently in force. However, there are certain specialities with respect to the definition of securities (see below).

Moreover, a specialized investment fund may – like under the law currently in force – have 100 investors at maximum. Unlike the law currently in force there is a look-through approach with respect to partnerships as investors, i.e. each partner of such partnership is counted as one investor of the investment fund.

Under the new law individuals may invest directly in a specialized investment fund, provided that they hold their specialized investment fund interest as part of their business assets. This is new compared to the law currently in force and the first drafts of the German Investment Tax Reform Act.

As a base case specialized investment funds are subject to the general tax rules for investment funds described below. However, they may opt for a semi-transparent tax regime which is the one known under the law currently in force. However certain amendments have been made to this system in the course of the investment tax reform.

5. Tax-exempt Capital Gains

In recent year there was an ongoing controversial discussion to abolish the exemption for capital gains from the sale or disposition of shares in a corporation (§8b para.2 German Corporation Tax Act) in cases of shareholdings of less than 10%. While there was a respective provision in the first draft of the German Investment Tax Reform Act such provision was not part of successor drafts and the final Act.

Thus, such capital gains remain tax-exempt in the future irrespective of any ownership percentages. However, it cannot be fully ruled out that this matter will be subject to discussion again, in particular after the Federal Election in 2017.

III. Further Changes During the Legislative Process

The following section provides an overview on certain material changes between the drafts of the German Investment Tax Act and the law that finally passed the German parliament (Bundestag). Reference is also made to our prior client information dated 7 August 2015 and 7 January 2016.

1. No CFC/PFIC Taxation

While there were no explicit provision in prior drafts it was common sense that CFC/PFIC taxation under the German Foreign Tax Act is not applicable on investment funds. There is a provision in the German Foreign Tax Act that provides that in cases of investment funds the provisions of the German Investment Tax Act prevail. Moreover, unlike the law currently in force (cf. §19 para.4 of the German Investment Tax Act) there is no provision in the new law that makes an exception to this rule.

Nevertheless, in the final Act it is clarified that the provisions of the German Investment Tax Act prevail because certain technical amendments were made to the provisions of the German Foreign Tax Act without doubting the general rule.

2. No Partial Exemption for Investment Fund Interests Held for Trading

Similar to the partial income taxation the and corporation tax exemption for dividends and capital gains the partial exemption for equity funds (Aktienteilfreistellung, see above) is intended to reflect any taxation of the company at the level of its shareholder. However, the corporation tax exemption is, inter alia, not applicable for life and healthcare insurance companies (cf. §8b para.8 German Corporation Tax Act). Accordingly, the partial exemption for equity funds was not available for life and healthcare insurance companies under the prior drafts.

The corporation tax exemption pursuant to §8b of the German Corporation Tax Act and the partial income taxation are also not available for shares held for trade by banks and financial institution and financial enterprises that acquired shares with the objective to achieve a short-term gain. Now, the final Act provides that partial exemption for equity funds (Aktienteilfreistellung) is also not available for these types of investors.

I. Changes with Regard to Specialized Investment Funds

As provided in prior drafts, a modification of semi-transparent taxation will continue to be applicable for specialized investment funds also post-2017. In addition to certain qualitative and quantitative restrictions regarding eligible investors, a classification as specialized investment fund depends on the applicability of, and compliance with, certain product rules. These product rules have been modified in the final Act.

1. Re-introduction of Manager Principle

Classification as a specialized investment fund requires that the fund is subject to investment regulation. In deviation from what applies under the law currently in force, a prior draft provided that the fund vehicle itself had to be subject to investment regulation. According to the final Act, the regulation requirement is met if either the fund or its manager is subject to investment regulation. Therefore, for instance the following structures can qualify for treatment as specialized investment funds:

  • specialized investment funds under the Luxembourg Law of 13February 2007, whose managers are not authorized pursuant to AIFMD; and
  • unregulated Luxembourg funds which are managed by a manager authorized under AIFMD.

2. Modifications Regarding Assets Eligible as Securities

The criteria for specialized investment funds contain an exclusive list of eligible assets in which 90% of a fund's NAV must be invested in order for the fund to qualify as specialized investment fund. The previous draft had contained a security definition which was in line with the definition of transferable securities under the UCITS Directive.

In the final Act the definition of "security" has been extended to cover other assets which are eligible to be acquired by UCITS up to 10% of their net asset value. This includes transferable securities pursuant to Directive 2007/16/EC ("Eligible Assets Directive") even if they are not listed. However, the 10% limitation does not apply for purposes of the criteria for specialized investment funds.

Based on the official reasoning it seems that the new definition, deviating from the so far applicable economic security definition, is supposed to be exhaustive in order to avoid indirect investments (e.g. using securitization vehicles) in assets which do not comply with the criteria for specialized investment funds. This statement gives rise to questions and is not quite comprehensible to us, since securitization vehicles typically issue securities. Until the legislator or the tax authorities release a desirable clarification, there is a legal uncertainty in connection with private equity and other closed-end fund products structured as investments in securities.

3. Requirements for Participations in Other Investment Funds

The final Act contains further modifications with respect to the eligibility of participations in other funds. Generally, interests in funds may qualify as investment fund interests, as securities, or as participations in corporations. Certain limitations which apply to securities or participations in corporations will not apply if classification as an investment fund interest is possible. In contrast to the previous draft, the final Act does not exclude participations in open-ended retail funds from qualification as investment fund interests. However, also contrary to the previous draft, target funds and their managers must be subject to an investment supervision.

IV. Value Added Tax

In its decision dated 9December 2015 (C-595/13; Fiscale Eenheid), the European Court of Justice ("ECJ") has held that the management of real estate funds that are subject to specific state supervision is VAT exempt according to Article13B(d)(6) of Directive 77/388/EWG (now Article135(1)(g) of the Directive on the Common System of Value Added Tax, "VAT Directive").

This decision has a direct impact on other types of funds including German closed-ended AIF such as private equity funds (cf. section 1 below). The adaption of the German VAT law which has definitely become necessary due to the decision has been made by the German Investment Tax Reform Act; it is doubtful whether this adaption is sufficient (cf. section 2 below).

1. Consequences of the Decision

Unlike in the most EU member states, the management of closed-ended AIFs (such as private equity funds) is not VAT-exempt in Germany. This is due to the fact that Germany interprets the VAT exemption granted by the VAT Directive for "the management of special investment funds as defined by Member States" very narrowly. The German legislation transposing this VAT exemption into national law (Sec.4(8) lit.h) German VAT Act) is limited to investment funds (Investmentfonds) within the meaning of the German Investment Tax Act currently in force (i.e. basically UCITS and open-ended real estate funds).

Based on the ECJ's reasoning, closed-ended AIF that are subject to the regulation under the German Capital Investment Code (i.e. the German AIFM law) must be granted the VAT exemption. The same should apply to AIFs or AIFMs which are subject to the EuVECA Directive (i.e. a distinct extensive supervisory regime).

Based on the reasoning of the ECJ the decisive point is that the power of the Member States to define the investment vehicles that fall into the scope of the exemption under the VAT Directive is superseded by the harmonized European regulatory law. Accordingly, not only UCITS fall within the scope of such exemption but also AIFs. The latter are comparable to UCITS if and because they are regulated.

2. Adaption by the German Investment Tax Reform Act

The German Investment Tax Reform Act provides that the management of UCITS and AIFs that are comparable to UCITS is VAT-exempt as of 1January 2018.

While the law itself does not elaborate the criteria that have to be satisfied for an AIF to be comparable to UCITS such criteria are set forth in the (non-binding) official reasoning of the German Investment Tax Reform Act. Under such criteria an AIF, inter alia,

  • must be subject to a comparable regulation like UCITS and
  • must have the same types of investors like UCITS.

As discussed at least BaFin regulation under the German Capital Investment Code or EuVECA should be comparable in this regard. There may be doubt whether so-called subthreshold specialized AIFMs and "small" retail AIFMs (§2 para.4 and 4a of the German Capital Investment Code) and AIFM of retail AIFs (§2 para.5 of the German Capital Investment Code) are subject to a special regulation such that the management of such AIFs is VAT-exempt. However, to strengthen the fund industry in Germany and for systematic reasons we hope that this question will be affirmed.

Another problem is that the official reasoning of the German Investment Tax Reform Act requires that AIFs must have the same types of investors like UCITS to benefit from the VAT-exemption. If this referred to retail investors this would not be covered by decisions of the ECJ. Moreover, even under current law the majority of VAT-exempt investment funds are specialized investment funds having institutional investors. However, based on the official reasoning the intention is that such specialized investment funds are nevertheless to benefit from VAT-exemption in the future.

Unfortunately, the amendments to the German VAT Act shall enter into force on 1January 2018. Given that the law currently in force is not in line with European law the amendments should enter into force immediately.

Hopefully, the legislation and/or the tax authorities solve any of these outstanding issues and amend the law where needed.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

To print this article, all you need is to be registered on Mondaq.com.

Click to Login as an existing user or Register so you can print this article.

Authors
Similar Articles
Relevancy Powered by MondaqAI
P+P Pollath + Partners
Deloitte Luxembourg
 
Some comments from our readers…
“The articles are extremely timely and highly applicable”
“I often find critical information not available elsewhere”
“As in-house counsel, Mondaq’s service is of great value”

Related Topics
 
Similar Articles
Relevancy Powered by MondaqAI
P+P Pollath + Partners
Deloitte Luxembourg
Related Articles
 
Related Video
Up-coming Events Search
Tools
Print
Font Size:
Translation
Channels
Mondaq on Twitter
 
Register for Access and our Free Biweekly Alert for
This service is completely free. Access 250,000 archived articles from 100+ countries and get a personalised email twice a week covering developments (and yes, our lawyers like to think you’ve read our Disclaimer).
 
Email Address
Company Name
Password
Confirm Password
Position
Mondaq Topics -- Select your Interests
 Accounting
 Anti-trust
 Commercial
 Compliance
 Consumer
 Criminal
 Employment
 Energy
 Environment
 Family
 Finance
 Government
 Healthcare
 Immigration
 Insolvency
 Insurance
 International
 IP
 Law Performance
 Law Practice
 Litigation
 Media & IT
 Privacy
 Real Estate
 Strategy
 Tax
 Technology
 Transport
 Wealth Mgt
Regions
Africa
Asia
Asia Pacific
Australasia
Canada
Caribbean
Europe
European Union
Latin America
Middle East
U.K.
United States
Worldwide Updates
Registration (you must scroll down to set your data preferences)

Mondaq Ltd requires you to register and provide information that personally identifies you, including your content preferences, for three primary purposes (full details of Mondaq’s use of your personal data can be found in our Privacy and Cookies Notice):

  • To allow you to personalize the Mondaq websites you are visiting to show content ("Content") relevant to your interests.
  • To enable features such as password reminder, news alerts, email a colleague, and linking from Mondaq (and its affiliate sites) to your website.
  • To produce demographic feedback for our content providers ("Contributors") who contribute Content for free for your use.

Mondaq hopes that our registered users will support us in maintaining our free to view business model by consenting to our use of your personal data as described below.

Mondaq has a "free to view" business model. Our services are paid for by Contributors in exchange for Mondaq providing them with access to information about who accesses their content. Once personal data is transferred to our Contributors they become a data controller of this personal data. They use it to measure the response that their articles are receiving, as a form of market research. They may also use it to provide Mondaq users with information about their products and services.

Details of each Contributor to which your personal data will be transferred is clearly stated within the Content that you access. For full details of how this Contributor will use your personal data, you should review the Contributor’s own Privacy Notice.

Please indicate your preference below:

Yes, I am happy to support Mondaq in maintaining its free to view business model by agreeing to allow Mondaq to share my personal data with Contributors whose Content I access
No, I do not want Mondaq to share my personal data with Contributors

Also please let us know whether you are happy to receive communications promoting products and services offered by Mondaq:

Yes, I am happy to received promotional communications from Mondaq
No, please do not send me promotional communications from Mondaq
Terms & Conditions

Mondaq.com (the Website) is owned and managed by Mondaq Ltd (Mondaq). Mondaq grants you a non-exclusive, revocable licence to access the Website and associated services, such as the Mondaq News Alerts (Services), subject to and in consideration of your compliance with the following terms and conditions of use (Terms). Your use of the Website and/or Services constitutes your agreement to the Terms. Mondaq may terminate your use of the Website and Services if you are in breach of these Terms or if Mondaq decides to terminate the licence granted hereunder for any reason whatsoever.

Use of www.mondaq.com

To Use Mondaq.com you must be: eighteen (18) years old or over; legally capable of entering into binding contracts; and not in any way prohibited by the applicable law to enter into these Terms in the jurisdiction which you are currently located.

You may use the Website as an unregistered user, however, you are required to register as a user if you wish to read the full text of the Content or to receive the Services.

You may not modify, publish, transmit, transfer or sell, reproduce, create derivative works from, distribute, perform, link, display, or in any way exploit any of the Content, in whole or in part, except as expressly permitted in these Terms or with the prior written consent of Mondaq. You may not use electronic or other means to extract details or information from the Content. Nor shall you extract information about users or Contributors in order to offer them any services or products.

In your use of the Website and/or Services you shall: comply with all applicable laws, regulations, directives and legislations which apply to your Use of the Website and/or Services in whatever country you are physically located including without limitation any and all consumer law, export control laws and regulations; provide to us true, correct and accurate information and promptly inform us in the event that any information that you have provided to us changes or becomes inaccurate; notify Mondaq immediately of any circumstances where you have reason to believe that any Intellectual Property Rights or any other rights of any third party may have been infringed; co-operate with reasonable security or other checks or requests for information made by Mondaq from time to time; and at all times be fully liable for the breach of any of these Terms by a third party using your login details to access the Website and/or Services

however, you shall not: do anything likely to impair, interfere with or damage or cause harm or distress to any persons, or the network; do anything that will infringe any Intellectual Property Rights or other rights of Mondaq or any third party; or use the Website, Services and/or Content otherwise than in accordance with these Terms; use any trade marks or service marks of Mondaq or the Contributors, or do anything which may be seen to take unfair advantage of the reputation and goodwill of Mondaq or the Contributors, or the Website, Services and/or Content.

Mondaq reserves the right, in its sole discretion, to take any action that it deems necessary and appropriate in the event it considers that there is a breach or threatened breach of the Terms.

Mondaq’s Rights and Obligations

Unless otherwise expressly set out to the contrary, nothing in these Terms shall serve to transfer from Mondaq to you, any Intellectual Property Rights owned by and/or licensed to Mondaq and all rights, title and interest in and to such Intellectual Property Rights will remain exclusively with Mondaq and/or its licensors.

Mondaq shall use its reasonable endeavours to make the Website and Services available to you at all times, but we cannot guarantee an uninterrupted and fault free service.

Mondaq reserves the right to make changes to the services and/or the Website or part thereof, from time to time, and we may add, remove, modify and/or vary any elements of features and functionalities of the Website or the services.

Mondaq also reserves the right from time to time to monitor your Use of the Website and/or services.

Disclaimer

The Content is general information only. It is not intended to constitute legal advice or seek to be the complete and comprehensive statement of the law, nor is it intended to address your specific requirements or provide advice on which reliance should be placed. Mondaq and/or its Contributors and other suppliers make no representations about the suitability of the information contained in the Content for any purpose. All Content provided "as is" without warranty of any kind. Mondaq and/or its Contributors and other suppliers hereby exclude and disclaim all representations, warranties or guarantees with regard to the Content, including all implied warranties and conditions of merchantability, fitness for a particular purpose, title and non-infringement. To the maximum extent permitted by law, Mondaq expressly excludes all representations, warranties, obligations, and liabilities arising out of or in connection with all Content. In no event shall Mondaq and/or its respective suppliers be liable for any special, indirect or consequential damages or any damages whatsoever resulting from loss of use, data or profits, whether in an action of contract, negligence or other tortious action, arising out of or in connection with the use of the Content or performance of Mondaq’s Services.

General

Mondaq may alter or amend these Terms by amending them on the Website. By continuing to Use the Services and/or the Website after such amendment, you will be deemed to have accepted any amendment to these Terms.

These Terms shall be governed by and construed in accordance with the laws of England and Wales and you irrevocably submit to the exclusive jurisdiction of the courts of England and Wales to settle any dispute which may arise out of or in connection with these Terms. If you live outside the United Kingdom, English law shall apply only to the extent that English law shall not deprive you of any legal protection accorded in accordance with the law of the place where you are habitually resident ("Local Law"). In the event English law deprives you of any legal protection which is accorded to you under Local Law, then these terms shall be governed by Local Law and any dispute or claim arising out of or in connection with these Terms shall be subject to the non-exclusive jurisdiction of the courts where you are habitually resident.

You may print and keep a copy of these Terms, which form the entire agreement between you and Mondaq and supersede any other communications or advertising in respect of the Service and/or the Website.

No delay in exercising or non-exercise by you and/or Mondaq of any of its rights under or in connection with these Terms shall operate as a waiver or release of each of your or Mondaq’s right. Rather, any such waiver or release must be specifically granted in writing signed by the party granting it.

If any part of these Terms is held unenforceable, that part shall be enforced to the maximum extent permissible so as to give effect to the intent of the parties, and the Terms shall continue in full force and effect.

Mondaq shall not incur any liability to you on account of any loss or damage resulting from any delay or failure to perform all or any part of these Terms if such delay or failure is caused, in whole or in part, by events, occurrences, or causes beyond the control of Mondaq. Such events, occurrences or causes will include, without limitation, acts of God, strikes, lockouts, server and network failure, riots, acts of war, earthquakes, fire and explosions.

By clicking Register you state you have read and agree to our Terms and Conditions