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Participating Member State, although certain Participating Member States are entitled to apply a withholding<br />
tax system during a transitional period. The transitional period commenced July 1, 2005 and will terminate at<br />
<strong>the</strong> end <strong>of</strong> <strong>the</strong> first full fiscal year after <strong>the</strong> EU and certain non-EU states reach an agreement on <strong>the</strong> exchange<br />
<strong>of</strong> such information. The EU Savings Directive came into effect July 1, 2005.<br />
According to <strong>the</strong> Luxembourg law <strong>of</strong> June 21, 2005 that implemented <strong>the</strong> EU Savings Directive, and certain<br />
bilateral agreements entered into by Luxembourg, during <strong>the</strong> transitional period, a Luxembourg Paying Agent<br />
may be required to withhold taxes on interest payments to Residual Entities or to Actual Owners (as defined<br />
below) who reside in an EU Member State or relevant dependant and associated territories at a rate <strong>of</strong> 20%<br />
(<strong>the</strong> rate will increase to 35% on July 1, 2011), unless <strong>the</strong> Actual Owner has opted for <strong>the</strong> alternative procedure<br />
proposed by <strong>the</strong> Luxembourg Paying Agent (exchange <strong>of</strong> information or a tax certificate).<br />
For <strong>the</strong> purpose <strong>of</strong> <strong>the</strong> previous two paragraphs, <strong>the</strong> terms Paying Agent, Interest and Actual Owner<br />
shall mean respectively agent payeur, intérêt and bénéficiaire économique as <strong>the</strong>se terms are defined in<br />
<strong>the</strong> law <strong>of</strong> June 21, 2005, and Residual Entity shall refer to <strong>the</strong> entities described in article 4.2 <strong>of</strong> <strong>the</strong> same<br />
law.<br />
Holders <strong>of</strong> <strong>the</strong> Securities should consult <strong>the</strong>ir own tax advisers regarding <strong>the</strong> implications <strong>of</strong> <strong>the</strong> EU Savings<br />
Directive in <strong>the</strong>ir particular circumstances. Pursuant to <strong>the</strong> law <strong>of</strong> December 23, 2005 that became effective<br />
on January 1, 2006, Luxembourg introduced a withholding tax <strong>of</strong> 10% for interest payments made to Luxembourg<br />
individual residents by a Luxembourg paying agent (as this term is defined in <strong>the</strong> law <strong>of</strong> December 23,<br />
2005). For a Security Holder, who is an individual who is a resident <strong>of</strong> Luxembourg acting in <strong>the</strong> course <strong>of</strong><br />
managing his private wealth, <strong>the</strong> 10% withholding tax is a final flat tax.<br />
8.5.2 Taxes on Income and Capital Gains<br />
A holder <strong>of</strong> <strong>the</strong> Securities who derives income from such Securities or who realises a gain on <strong>the</strong> disposal or<br />
redemption <strong>the</strong>re<strong>of</strong> will not be subject to Luxembourg taxation on such income or capital gains unless:<br />
(a) such holder is, or is deemed to be, resident in Luxembourg for <strong>the</strong> purposes <strong>of</strong> <strong>the</strong> relevant provisions;<br />
or<br />
(b) such income or gain is attributable to an enterprise or part <strong>the</strong>re<strong>of</strong> which is carried on through a permanent<br />
establishment, a permanent representative or a fixed <strong>base</strong> <strong>of</strong> business in Luxembourg.<br />
8.5.3 Net Wealth Tax<br />
Luxembourg net wealth tax will not be levied on a holder <strong>of</strong> <strong>the</strong> Securities unless:<br />
(a) such holder is, or is deemed to be, resident in Luxembourg for <strong>the</strong> purpose <strong>of</strong> <strong>the</strong> relevant provisions;<br />
or<br />
(b) such Securities are attributable to an enterprise or part <strong>the</strong>re<strong>of</strong> which is carried on through a permanent<br />
establishment, a permanent representative or a fixed <strong>base</strong> <strong>of</strong> business in Luxembourg.<br />
With <strong>the</strong> law <strong>of</strong> December 23, 2005, <strong>the</strong> net wealth tax has been abolished for resident and non-resident individuals<br />
with effect from 1, January 2006.<br />
8.5.4 Inheritance and Gift Tax<br />
Where <strong>the</strong> Securities are transferred for no consideration, note in particular that:<br />
(a) no Luxembourg inheritance tax is levied on <strong>the</strong> transfer <strong>of</strong> <strong>the</strong> Securities upon death <strong>of</strong> a holder <strong>of</strong> <strong>the</strong><br />
Securities in cases where <strong>the</strong> deceased holder was not a resident <strong>of</strong> Luxembourg for inheritance tax<br />
purposes; and<br />
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