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JPMORGAN CHASE & CO. - Irish Stock Exchange

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TAXATION OF THE NOTES<br />

Taxation<br />

Except where specifically discussed below, the following summaries of certain taxation provisions in the United States<br />

and Ireland do not consider the tax treatment of payments in respect of Notes linked or related to one or more Reference<br />

Items. The taxation provisions applicable to such Notes may be different (and in some cases significantly different)<br />

from those described in the summaries below.<br />

The section headed “U.S. Holders” is relevant in relation to U.S. Holders acquiring Registered Notes and the section<br />

headed “Non-U.S. Holder” is relevant in relation to Non-U.S. Holders acquiring Bearer Notes and Registered Notes.<br />

Purchasers and/or sellers of Notes may be required to pay stamp taxes and other charges in accordance with the laws<br />

and practices of the country of transfer or purchase in addition to the issue price or purchase price (if different) of the<br />

Notes.<br />

Transactions involving Notes (including purchases, transfer or redemption), the accrual or receipt of any interest<br />

payable on the Notes and the death of a holder of any Note may have tax consequences for potential purchasers which<br />

may depend, amongst other things, upon the tax status of the potential purchaser and may relate to stamp duty, stamp<br />

duty reserve tax, income tax, corporation tax, capital gains tax and inheritance tax.<br />

Condition 7 (on pages 61 to 62) should be considered carefully by all potential purchasers of Notes.<br />

The provisions relating to payment of Delivery Expenses by the relevant Noteholder on physical delivery of the Asset<br />

Amount(s) set out in Condition 6(l) (on pages 59 to 61) should be considered carefully by all potential purchasers of<br />

Notes which may be redeemed by delivery of Asset Amount(s).<br />

Potential purchasers who are in any doubt about their tax position on purchase, ownership or transfer of any Notes<br />

should consult their own tax advisers.<br />

United States Taxation<br />

TO ENSURE <strong>CO</strong>MPLIANCE WITH TREASURY DEPARTMENT CIRCULAR 230, HOLDERS ARE HEREBY<br />

NOTIFIED THAT: (A) ANY DISCUSSION OF UNITED STATES FEDERAL TAX ISSUES IN THIS BASE<br />

PROSPECTUS IS NOT INTENDED OR WRITTEN TO BE RELIED UPON, AND CANNOT BE RELIED UPON,<br />

BY HOLDERS FOR THE PURPOSE OF AVOIDING PENALTIES THAT MAY BE IMPOSED ON HOLDERS<br />

UNDER THE UNITED STATES INTERNAL REVENUE <strong>CO</strong>DE; (B) SUCH DISCUSSION IS INCLUDED HEREIN<br />

BY THE ISSUER IN <strong>CO</strong>NNECTION WITH THE PROMOTION OR MARKETING (WITHIN THE MEANING OF<br />

CIRCULAR 230) BY THE ISSUER OF THE TRANSACTIONS OR MATTERS ADDRESSED HEREIN; AND (C)<br />

HOLDERS SHOULD SEEK ADVICE BASED ON THEIR PARTICULAR CIRCUMSTANCES FROM AN<br />

INDEPENDENT TAX ADVISER.<br />

The following is a summary of certain material U.S. federal income tax consequences of the acquisition, ownership and<br />

disposition of Notes by a U.S. Holder and Non-U.S. Holder (each as defined below). This summary does not address<br />

the material U.S. federal income tax consequences of every type of Note which may be issued under the Programme.<br />

The relevant Final Terms or any Prospectus or series prospectus will contain additional or modified disclosure<br />

concerning the material U.S. federal income tax consequences relevant to such type of Note as appropriate.<br />

The summary is based on the tax laws of the United States including the United States Internal Revenue Code of 1986,<br />

as amended, its legislative history, existing and proposed regulations thereunder, published rulings and court decisions,<br />

all as of the date hereof and all subject to change at any time, possibly with retroactive effect.<br />

73

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