080305_JPM Series Fix and Win ... - Börse Stuttgart

corporation for U.S. federal income tax purposes (such person a "U.S. Controlled Person") or with respect to
certain debt instruments in registered form may be subject to information reporting and may be subject to U.S.
backup withholding unless the United States Alien has provided applicable certification of foreign status or
otherwise establishes an exemption. Subject to the foregoing, unless the Issuer or the paying agent has actual
knowledge or reason to know that the holder or beneficial owner, as the case may be, is a United States Person,
payments on and proceeds from the sale of the Instruments made outside the United States generally will be
exempt from the U.S. backup withholding and, if made by or through a person that is not a U.S. Controlled
Person the information reporting rules. Any amounts withheld under the backup withholding rules may be
allowed as a credit against the holder’s U.S. federal income tax liability, and may entitle the holder to a refund,
provided that the required information is furnished to the U.S. Internal Revenue Service.
Holders should consult their tax advisors regarding the application of information reporting and backup
withholding to their particular situations, the availability of an exemption therefrom, and the procedure for
obtaining an exemption, if available.
THE SUMMARY OF U.S. FEDERAL INCOME AND ESTATE TAX MATTERS SET FORTH ABOVE IS
INCLUDED FOR GENERAL INFORMATION ONLY. ALL PROSPECTIVE PURCHASERS ARE URGED
TO CONSULT THEIR OWN TAX ADVISERS AS TO THE PARTICULAR TAX CONSEQUENCES TO
THEM OF OWNING INSTRUMENTS, INCLUDING THE APPLICABILITY AND EFFECT OF U.S.
FEDERAL, STATE, LOCAL, NON-U.S. AND OTHER TAX LAWS AND POSSIBLE CHANGES IN TAX
LAW.
Jersey Taxation
Under the current prevailing tax law of Jersey and extra-statutory concessions granted to JPMIDL and JPMCB
by the Jersey income tax authorities, the proceeds gained from the exercise, sale or other disposition of JPMIDL
Instruments by a Holder of such Instruments (in the following sections regarding Jersey Taxation, "Notes" and
"Instruments" refers to securities issued under the Programme generally) who is not resident in Jersey for the
purposes of the Income Tax (Jersey) Law 1961, as amended (the "Jersey Income Tax Law"), and payments
made in respect of such Instruments to such Holder, will not be subject to any assessment for taxes (including
withholding taxes) in Jersey. Any Holder of JPMIDL or JPMCB Instruments resident in Jersey for the purposes
of the Jersey Income Tax Law will, however, be obliged, under that Law, to include in any statement delivered
under that Law of the profits or gains arising to that Holder a true, complete and correct statement of the amount
of the profits or gains arising to that Holder from that Holder's holding of such Instruments.
No stamp or transfer tax is payable in Jersey on the exercise, sale or other disposition of such Instruments by a
holder of such Instruments. Probate or Letters of Administration may be required to be obtained in Jersey on the
death of an individual holder of such Instruments. Stamp duty is payable in Jersey on the registration of such
Probate or Letters of Administration on the value of the Holder's estate in Jersey.
European Union Directive on the Taxation of Savings Income
As part of an agreement reached in connection with the European Union ("EU") directive on the taxation of
savings income in the form of interest payments, and in line with steps taken by other relevant third countries,
Jersey introduced with effect from 1 July 2005 a retention tax system in respect of payments of interest, or other
similar income, made to an individual beneficial owner resident in an EU Member State by a paying agent
established in Jersey. The retention tax system applies for a transitional period prior to the implementation of a
system of automatic communication to EU Member States of information regarding such payments. During this
transitional period, such an individual beneficial owner resident in an EU Member State will be entitled to
request a paying agent not to retain tax from such payments but instead to apply a system by which the details of
such payments are communicated to the tax authorities of the EU Member State in which the beneficial owner is
resident.
The retention tax system in Jersey is implemented by means of bilateral agreements with each of the EU
Member States, the Taxation (Agreements with European Union Member States) (Jersey) Regulations 2005 and
Guidance Notes issued by the Policy & Resources Committee of the States of Jersey. Based on these provisions
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