Gresham Capital CLO IV B.V. - Irish Stock Exchange

TAX CONSIDERATIONS
General
The following is a summary, based upon present law, of certain Dutch, German, United Kingdom and U.S.
federal income tax considerations for prospective purchasers of the Notes. The discussion does not consider the
circumstances of particular purchasers, some of which (such as banks, insurance companies, dealers, traders,
financial institutions, real estate investment trusts, regulated investment companies, grantor trusts, tax exempt
organisations or persons holding the Notes as part of a hedge, straddle, conversion, integrated transaction or
constructive sale transaction with other investments) are subject to special tax regimes. The discussion is a
general summary; it is not a substitute for tax advice.
EACH PROSPECTIVE PURCHASER IS URGED TO CONSULT ITS OWN TAX ADVISER ABOUT
THE TAX CONSEQUENCES OF AN INVESTMENT IN THE NOTES UNDER THE LAWS OF THE
NETHERLANDS, THE UNITED STATES AND ITS CONSTITUENT JURISDICTIONS, AND ANY
OTHER JURISDICTIONS WHERE THE PURCHASER MAY BE SUBJECT TO TAXATION.
Purchasers of Notes may be required to pay stamp taxes and other charges in accordance with the laws and
practices of the country of purchase in addition to the issue price of each Note.
Potential purchasers who are in any doubt about their tax position on purchase, ownership, transfer or
exercise of any rights in respect of any Note should consult their own tax advisers. In particular, no
representation is made as to the manner in which payments under the Notes would be characterised by
any relevant taxing authority.
Taxation of The Netherlands
The comments below are of a general nature based on taxation law and practice in The Netherlands as at
the date of this Prospectus and are subject to any changes therein. They relate only to the position of persons
who are absolute beneficial owners of the Notes. The following is a general description of certain tax
considerations relating to the Notes. It does not purport to be a complete analysis of all tax considerations
relating to the Notes and so should be treated with appropriate caution. In particular, it does not take into
consideration any tax implications that may arise on a substitution of the Issuer. Prospective investors should
consult their own professional advisors concerning the possible tax consequences of purchasing, holding and/or
selling Notes and receiving payments of interest, principal and/or other amounts under the Notes under the
applicable laws of their country of citizenship, residence or domicile.
Under the existing laws of The Netherlands:
(a) all payments of interest and principal by the Issuer under the Notes can be made free of withholding or
deduction for any taxes of whatsoever nature imposed, levied, withheld, or assessed by The
Netherlands or any political subdivision or taxing authority thereof or therein;
(b) a holder of a Note who derives income from a Note or who realises a gain on the disposal or
redemption of a Note will not be subject to Dutch taxation on such income or capital gain, unless:
(i) the holder is, or is deemed to be, resident in The Netherlands or, where the holder is an individual,
such holder has elected to be treated as a resident of The Netherlands; or
(ii) such income or gain is attributable to an enterprise or part thereof which is either effectively
managed in The Netherlands or carried on through a permanent establishment (vaste inrichting) or
a permanent representative (vaste vertegenwoordiger) in The Netherlands; or
(iii) the holder is an individual and such income or gain qualifies as income from activities that exceed
normal active portfolio management in The Netherlands;
(c) Dutch gift, estate or inheritance taxes will not be levied on the occasion of the transfer of a Note by
way of gift by, or on the death of, a holder unless:
(i) the holder is, or is deemed to be, resident in The Netherlands for the purpose of the relevant
provisions; or
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