TIDM42BI
RNS Number : 5858I
Inter-American Development Bank
09 December 2015
PRICING SUPPLEMENT
Inter-American Development Bank
Global Debt Program
Series No: 540
U.S.$5,000,000 Callable Step-Rate Notes due November 30,
2020
Issue Price: 100.00 percent
Wells Fargo Securities
The date of this Pricing Supplement is November 24, 2015.
Terms used herein shall be deemed to be defined as such for the
purposes of the Terms and Conditions (the "Conditions") set forth
in the Prospectus dated January 8, 2001 (the "Prospectus") (which
for the avoidance of doubt does not constitute a prospectus for the
purposes of Part VI of the United Kingdom Financial Services and
Markets Act 2000 or a base prospectus for the purposes of Directive
2003/71/EC of the European Parliament and of the Council). This
Pricing Supplement must be read in conjunction with the Prospectus.
This document is issued to give details of an issue by the
Inter-American Development Bank (the "Bank") under its Global Debt
Program and to provide information supplemental to the Prospectus.
Complete information in respect of the Bank and this offer of the
Notes is only available on the basis of the combination of this
Pricing Supplement and the Prospectus.
Terms and Conditions
The following items under this heading "Terms and Conditions"
are the particular terms which relate to the issue the subject of
this Pricing Supplement. These are the only terms which form part
of the form of Notes for such issue.
1. Series No.: 540
2. Aggregate Principal Amount: U.S.$5,000,000
3. Issue Price: U.S.$5,000,000 which is 100.00
percent of the Aggregate Principal
Amount
4. Issue Date: November 30, 2015
5. Form of Notes
(Condition 1(a)): Registered only, as further provided
in paragraph 8 of "Other Relevant
Terms" below
6. Authorized Denomination(s)
(Condition 1(b)): U.S.$100,000 and integral multiples
thereof
7. Specified Currency
(Condition 1(d)): United States Dollars (U.S.$)
being the lawful currency of the
United States of America
8. Specified Principal Payment
Currency
(Conditions 1(d) and 7(h)): U.S.$
9. Specified Interest Payment
Currency U.S.$
(Conditions 1(d) and 7(h)):
10. Maturity Date
(Condition 6(a); Fixed November 30, 2020
Interest Rate):
11. Interest Basis
(Condition 5): Fixed Interest Rate (Condition
5(I))
12. Interest Commencement Date
(Condition 5(III)): Issue Date (November 30, 2015)
13. Fixed Interest Rate (Condition
5(I)):
(a) Interest Rate: From and including the Issue Date
to but excluding November 30, 2018:
1.15 percent per annum
From and including November 30,
2018 to but excluding November
30, 2020: 2.40 percent per annum
(b) Fixed Rate Interest
Payment Date(s): Quarterly in arrear on the last
calendar day in February, and on
the 30(th) of each May, August
and November, in each year, commencing
on February 29, 2016 and ending
on the Maturity Date.
Each Interest Payment Date is subject
to the Following Business Day Convention
with no adjustment to the amount
of interest otherwise calculated.
(c) Fixed Rate Day Count
Fraction(s): 30/360
14. Relevant Financial Center: New York and London
15. Relevant Business Days: New York and London
16. Issuer's Optional Redemption
(Condition 6(e)): Yes, in whole but not in part
(a) Notice Period: No less than five (5) Relevant
Business Days prior to the Optional
Redemption Date
(b) Amount: 100.00 percent per Authorized Denomination
(c) Date(s): Quarterly on the last calendar
day in February, and on the 30(th)
of each May, August and November,
in each year, commencing on November
30, 2018 to and including August
30, 2020
(d) Early Redemption Amount
Bank: 100.00 percent of the Aggregate
Principal Amount
17. Redemption at the Option
of the Noteholders (Condition No
6(f)):
18. Governing Law: New York
19. Selling Restrictions: Under the provisions of Section
(a) United States: 11(a) of the Inter-American Development
Bank Act, the Notes are exempted
securities within the meaning of
Section 3(a)(2) of the U.S. Securities
Act of 1933, as amended, and Section
3(a)(12) of the U.S. Securities
Exchange Act of 1934, as amended.
(b) United Kingdom: The Dealer represents and agrees
that it has complied and will comply
with all applicable provisions
of the Financial Services and Markets
Act 2000 with respect to anything
done by it in relation to such
Notes in, from or otherwise involving
the United Kingdom.
(c) Ecuador: The Dealer has acknowledged that
the Notes described herein have
not been and will not be offered
to the public within Ecuador. The
Notes are sold through a private
placement.
(d) General: No action has been or will be taken
by the Issuer that would permit
a public offering of the Notes,
or possession or distribution of
any offering material relating
to the Notes in any jurisdiction
where action for that purpose is
required. Accordingly, the Dealer
agrees that it will observe all
applicable provisions of law in
each jurisdiction in or from which
it may offer or sell Notes or distribute
any offering material.
Other Relevant Terms
1. Listing: None
2. Details of Clearance System
Approved by the Bank and
the
Global Agent and Clearance Depository Trust Company (DTC)
and
Settlement Procedures:
3. Syndicated: No
4. Commissions and Concessions: 0.30% of the Aggregate Nominal
Amount
5. Estimated Total Expenses: None. The Dealer has agreed to
(MORE TO FOLLOW) Dow Jones Newswires
December 10, 2015 02:00 ET (07:00 GMT)
pay for all material expenses related
to the issuance of the Notes.
6. Codes:
(a) ISIN: US45818WBJ45
(b) CUSIP: 45818WBJ4
7. Identity of Dealer: Wells Fargo Securities, LLC
8. Provisions for Registered
Notes:
(a) Individual Definitive
Registered Notes Available
on Issue Date: No
(b) DTC Global Note(s): Yes, issued in accordance with
the Global Agency Agreement, dated
January 8, 2001, as amended, among
the Bank, Citibank, N.A. as Global
Agent, and the other parties thereto.
(c) Other Registered Global
Notes: No
General Information
Additional Information Regarding the Notes
1. The EU has adopted Council Directive 2003/48/EC on the
taxation of savings income (the "Savings Directive"). The Savings
Directive requires EU Member States to provide to the tax
authorities of other EU Member States details of payments of
interest and other similar income paid by a person established
within its jurisdiction to (or secured by such a person for the
benefit of) an individual resident, or to (or secured for) certain
other types of entity established, in that other EU Member State,
except that Austria will instead impose a withholding system for a
transitional period (subject to a procedure whereby, on meeting
certain conditions, the beneficial owner of the interest or other
income may request that no tax be withheld) unless during such
period it elects otherwise.
A number of non-EU countries and territories, including
Switzerland, have adopted similar measures.
The Bank undertakes that it will ensure that it maintains a
paying agent in a country which is an EU Member State that will not
be obliged to withhold or deduct tax pursuant to the Savings
Directive.
The Council of the European Union has adopted a Directive (the
"Amending Savings Directive") which would, when implemented, amend
and broaden the scope of the requirements of the Savings Directive
described above, including by expanding the range of payments
covered by the Savings Directive, in particular to include
additional types of income payable on securities, and by expanding
the circumstances in which payments must be reported or paid
subject to withholding. The Amending Savings Directive requires EU
Member States to adopt national legislation necessary to comply
with it by January 1, 2016, which legislation must apply from
January 1, 2017.
The Council of the European Union has also adopted a Directive
(the "Amending Cooperation Directive") amending Council Directive
2011/16/EU on administrative cooperation in the field of taxation
so as to introduce an extended automatic exchange of information
regime in accordance with the Global Standard released by the OECD
Council in July 2014. The Amending Cooperation Directive requires
EU Member States to adopt national legislation necessary to comply
with it by December 31, 2015, which legislation must apply from
January 1, 2016 (January 1, 2017 in the case of Austria). The
Amending Cooperation Directive is generally broader in scope than
the Savings Directive, although it does not impose withholding
taxes, and provides that to the extent there is overlap of scope,
the Amending Cooperation Directive prevails. The European
Commission has therefore published a proposal for a Council
Directive repealing the Savings Directive from January 1, 2016
(January 1, 2017 in the case of Austria) (in each case subject to
transitional arrangements). The proposal also provides that, if it
is adopted, EU Member States will not be required to implement the
Amending Savings Directive. Information reporting and exchange will
however still be required under Council Directive 2011/16/EU (as
amended).
2. United States Federal Income Tax Matters
The following supplements the discussion under the "Tax Matters"
section of the Prospectus regarding the U.S. federal income tax
treatment of the Notes, and is subject to the limitations and
exceptions set forth therein. Any tax disclosure in the Prospectus
or this pricing supplement is of a general nature only, is not
exhaustive of all possible tax considerations and is not intended
to be, and should not be construed to be, legal, business or tax
advice to any particular prospective investor. Each prospective
investor should consult its own tax advisor as to the particular
tax consequences to it of the acquisition, ownership, and
disposition of the Notes, including the effects of applicable U.S.
federal, state, and local tax laws and non-U.S. tax laws and
possible changes in tax laws.
Due to a change in law since the date of the Prospectus, the
second paragraph of "-Payments of Interest" under the "United
States Holders" section should be updated to read as follows:
"Interest paid by the Bank on the Notes constitutes income from
sources outside the United States and will, depending on the
circumstances, be "passive" or "general" income for purposes of
computing the foreign tax credit."
The Notes should not be treated as issued with original issue
discount ("OID") despite the fact that the interest rate on the
Notes is scheduled to step-up over the term of the Notes because
Treasury regulations generally deem an issuer to exercise a call
option in a manner that minimizes the yield on the debt instrument
for purposes of determining whether a debt instrument is issued
with OID. The yield on the Notes would be minimized if the Bank
calls the Notes immediately before the increase in the interest
rate on November 30, 2018, and therefore the Notes should be
treated for OID purposes as fixed-rate notes that will mature prior
to the step-up in interest rate for the Notes. This assumption is
made solely for U.S. federal income tax purposes of determining
whether the Notes are issued with OID and is not an indication of
the Bank's intention to call or not to call the Notes at any time.
If the Bank does not call the Notes prior to the increase in the
interest rate then, solely for OID purposes, the Notes will be
deemed to be reissued at their adjusted issue price on November 30,
2018. This deemed issuance should not give rise to taxable gain or
loss to holders.
Under this approach the coupon on a Note will generally be
taxable to a United States holder as ordinary interest income at
the time it accrues or is received in accordance with the United
States holder's normal method of accounting for tax purposes
(regardless of whether the Bank calls the Notes).
Upon the disposition of a Note by sale, exchange or redemption
(e.g., if the Bank exercises its right to call the Notes) or other
disposition, a United States holder will generally recognize
taxable gain or loss equal to the difference, if any, between (i)
the amount realized on the disposition (other than amounts
attributable to accrued but unpaid interest, which would be treated
as such) and (ii) the United States holder's adjusted tax basis in
the Note. A United States holder's adjusted tax basis in a Note
generally will equal the cost of the Note (net of accrued interest)
to the United States holder. Capital gain of individual taxpayers
from the sale, exchange, redemption, retirement or other
disposition of a Note held for more than one year may be eligible
for reduced rates of taxation. The deductibility of a capital loss
realized on the sale, exchange, redemption or other disposition of
a Note is subject to significant limitations.
Information with Respect to Foreign Financial Assets. Owners of
"specified foreign financial assets" with an aggregate value in
excess of U.S.$50,000 (and in some circumstances, a higher
threshold) may be required to file an information report with
respect to such assets with their tax returns. "Specified foreign
financial assets" may include financial accounts maintained by
foreign financial institutions, as well as the following, but only
if they are held for investment and not held in accounts maintained
by financial institutions: (i) stocks and securities issued by
non-United States persons, (ii) financial instruments and contracts
that have non-United States issuers or counterparties, and (iii)
interests in foreign entities. Holders are urged to consult their
tax advisors regarding the application of this reporting
requirement to their ownership of the Notes.
Medicare Tax. A United States holder that is an individual or
estate, or a trust that does not fall into a special class of
trusts that is exempt from such tax, is subject to a 3.8% tax (the
"Medicare tax") on the lesser of (1) the United States holder's
"net investment income" (or "undistributed net investment income"
in the case of an estate or trust) for the relevant taxable year
and (2) the excess of the United States holder's modified adjusted
gross income for the taxable year over a certain threshold (which
in the case of individuals is between U.S.$125,000 and
U.S.$250,000, depending on the individual's circumstances). A
holder's net investment income generally includes its interest
income and its net gains from the disposition of Notes, unless such
interest income or net gains are derived in the ordinary course of
the conduct of a trade or business (other than a trade or business
that consists of certain passive or trading activities). United
States holders that are individuals, estates or trusts are urged to
consult their tax advisors regarding the applicability of the
Medicare tax to their income and gains in respect of their
investment in the
(MORE TO FOLLOW) Dow Jones Newswires
December 10, 2015 02:00 ET (07:00 GMT)
Inter 2042 (LSE:42BI)
Historical Stock Chart
From Jun 2024 to Jul 2024
Inter 2042 (LSE:42BI)
Historical Stock Chart
From Jul 2023 to Jul 2024
