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ALBA 2007 – 1 plc - Irish Stock Exchange

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2. Provision of information<br />

2.1 Noteholders should note that where any interest on the Notes is paid to them (or to any person<br />

acting on their behalf) by the Issuer or any person in the United Kingdom acting on behalf of<br />

the Issuer (a ‘‘paying agent’’), or is received by any person in the United Kingdom acting on<br />

behalf of the relevant Noteholder (other than solely by clearing or arranging the clearing of a<br />

cheque) (a ‘‘collecting agent’’), then the Issuer, the paying agent or the collecting agent (as the<br />

case may be) may, in certain cases, be required to supply to HM Revenue and Customs details<br />

of the payment and certain details relating to the Noteholder (including the Noteholder’s name<br />

and address). These provisions will apply whether or not the interest has been paid subject to<br />

withholding or deduction for or on account of United Kingdom income tax and whether or not<br />

the Noteholder is resident in the United Kingdom for United Kingdom tax purposes. Where the<br />

Noteholder is not so resident, the details provided to HM Revenue and Customs may, in certain<br />

cases, be passed by HM Revenue and Customs to the tax authorities of the jurisdiction in which<br />

the Noteholder is resident for taxation purposes.<br />

2.2 With effect from 6 April <strong>2007</strong>, the provisions referred to above may also apply, in certain<br />

circumstances, to payments made on redemption of any Notes where the amount payable on<br />

redemption is greater than the issue price of the Notes.<br />

3. Other points relating to United Kingdom withholding tax<br />

3.1 Where interest has been paid under deduction of United Kingdom income tax, noteholders who<br />

are not resident in the United Kingdom may be able to recover all or part of the tax deducted if<br />

there is an appropriate provision in any applicable double taxation treaty.<br />

3.2 Where the Notes are to be, or may fall to be, redeemed at a premium, as opposed to being<br />

issued at a discount, any such element of premium may constitute a payment of interest.<br />

Payments of interest are subject to United Kingdom withholding tax and reporting requirements<br />

as outlined above.<br />

3.3 The references to ‘‘interest’’ above mean ‘‘interest’’ as understood in United Kingdom tax law.<br />

The statements above do not take any account of any different definitions of ‘‘interest’’ or<br />

‘‘principal’’ which may prevail under any other law or which may be created by the terms and<br />

conditions of the notes or any related documentation.<br />

4. Stamp duty and stamp duty reserve tax<br />

4.1 No United Kingdom stamp duty or stamp duty reserve tax is chargeable on the issue of the<br />

Notes or the Instruments.<br />

4.2 United Kingdom stamp duty may be chargable on any instruments transferring a MERC or a R<br />

Certificate (including where such Instruments are in Definitive Form) and Instrumentholders are<br />

advised to consult with their professional advisers in respect of matters relating to the<br />

acquisition and holding of the Instruments.

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