INFORMATION MEMORANDUM DATED 9 JULY 2009 ...

correctly follow such procedures. Moreover, the Issuer will not pay any additional
amounts with respect to any such withholding. See "Risk Factors – Risks in Relation to
Spanish Taxation". Beneficial Owners must seek their own advice to ensure that they
comply with all procedures to ensure the correct tax treatment of their Notes and should
consult the latest announcements in relation to the procedures on the ICSDs websites
(www.euroclear.com and www.clearstream.com).
Participants in the Clearing System who are Qualified Institutions who have been paid net of
Spanish withholding tax because of a failure to comply with the Immediate Refund Procedure
set forth in Article I of Appendix 1 to this Information Memorandum will be entitled to a
refund of the amount withheld pursuant to the Quick Refund Procedures set forth in Article II
of Appendix 1 to this Information Memorandum.
Beneficial Owners entitled to receive interest payments in respect of the Notes free of any
Spanish withholding taxes but in respect of whom relevant documentation is not timely
received by the Issuer under the Immediate Refund Procedure or the Quick Refund Procedures
may seek a full refund of withholding tax directly from the Spanish tax authorities following
the direct refund procedure established by Spanish tax law and described in Article III of
Appendix 1 to this Information Memorandum.
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