Ardagh Glass Finance plc - Irish Stock Exchange

Encashment Tax
If the Paying Agent is not in Ireland, which is the case, then there is no obligation to deduct
encashment tax. If a person in Ireland were to pay the interest or receive the interest on behalf of a
third party, then Irish encashment tax (at the standard rate—currently 20%) would apply to amounts
belonging to Irish resident holders of the Senior Notes, or non-Irish residents tax who hold Notes and
who had not completed the requisite non-resident declaration forms.
Deposit Interest Retention Tax (‘‘DIRT’’)
The interest on the Senior Notes will not be liable to DIRT as the Issuer is not a relevant deposit
taker as defined in Irish tax law.
Capital Gains Tax
In the case of a person who is either tax resident or ordinarily tax resident in Ireland, the disposal
or redemption of the Senior Notes may be liable to Irish capital gains tax at a rate of 25%. If the
person is neither resident nor ordinarily resident in Ireland, he will not be liable to Irish capital gains
tax on the disposal or redemption unless the Senior Notes are situated in Ireland and have been used
in or for the purposes of a trade carried on by such person in Ireland through a branch or agency, or
which were used or held or acquired for use by or for the purposes of the branch or agency. Registered
instruments will be deemed to be situated in Ireland if the register is located in Ireland at the time of
the disposal or redemption.
Capital Acquisitions Tax
A gift or inheritance of the Senior Notes will be within the charge to capital acquisitions tax where
the donor or the beneficiary in relation to the gift/inheritance is tax resident or ordinarily tax resident
in Ireland at the date of the gift/inheritance, or if the Senior Notes are regarded as property situated in
Ireland. Special rules with regard to tax residence apply where an individual is not domiciled in Ireland.
Capital acquisitions tax is charged at a rate of 25% on the taxable value of the gift or inheritance
above a tax-free threshold.
Value Added Tax (‘‘VAT’’)
There is no Irish VAT payable in respect of payments in consideration for the issue of the Senior
Notes or for the transfer of a Senior Note.
Stamp Duty
Issuance of Instruments
No stamp duty arises on the issuance of the Senior Notes.
Transfer of Senior Notes
No stamp duty is chargeable on a transfer of the Senior Notes as they meet the following
conditions for exemption under Irish tax legislation:
1. They do not carry a right of conversion into stocks or marketable securities (other than loan
capital) of a company having a register in Ireland or into loan capital having such a right;
2. They do not carry rights of the same kind as shares in the capital of the company, including
rights such as voting rights, a share in the profits or a share in the surplus upon liquidations;
3. They are issued for a price which is not less than 90% of the nominal value; and
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