Ardagh Glass Finance plc - Irish Stock Exchange

will hold Senior Notes as part of a ‘‘hedging’’ or ‘‘conversion’’ transaction or as a position in a
‘‘straddle’’ or as part of a ‘‘synthetic security’’ or other integrated transaction for U.S. federal income
tax purposes; (vi) persons that have a ‘‘functional currency’’ other than the U.S. dollar; (vii) regulated
investment companies; and (viii) persons that have ceased to be U.S. citizens or lawful permanent
residents of the U.S. Further, this summary does not address alternative minimum tax consequences or
U.S. federal estate and gift tax consequences.
This summary is based on the Code and U.S. Treasury regulations and judicial and administrative
interpretations thereof, as of the date of this Offering Memorandum. All of the foregoing are subject
to change, which change could apply retroactively and could affect the tax consequences described
below.
For purposes of this summary, a ‘‘U.S. Holder’’ is a beneficial owner of a Senior Note that is, for
U.S. federal income tax purposes: (i) an individual who is a citizen or resident of the United States;
(ii) a corporation, or other entity treated as a corporation, created or organized in or under the laws of
the United States, any state thereof or the District of Columbia; (iii) an estate, the income of which is
subject to U.S. federal income taxation regardless of its source; or (iv) a trust if (1) a court within the
United States is able to exercise primary supervision over the administration of the trust and one or
more U.S. persons have the authority to control all substantial decisions of the trust or (2) the trust
was in existence on August 20, 1996 and has properly elected to continue to be treated as a U.S.
person.
If any entity treated as a partnership or other pass-through entity for U.S. federal income tax
purposes holds Senior Notes, the tax treatment of a partner in or owner of the partnership or other
pass-through entity will generally depend upon the status of the partner or owner and the activities of
the entity. Holders that are a partner in or owner of a partnership or other pass-through entity that is
considering holding Senior Notes should consult their own tax advisors.
Each prospective investor should consult its own tax advisor with respect to the U.S. federal
(including income, estate and gift), state, local and foreign tax consequences of acquiring, owning and
disposing of Senior Notes. U.S. Holders should also review the discussion under ‘‘—Ireland Taxation’’
and ‘‘—United Kingdom Taxation’’ for the Irish and United Kingdom tax consequences to a U.S.
Holder of the ownership of Senior Notes.
Payments of Stated Interest
Stated interest paid on a Senior Note will be taxable to a U.S. Holder as ordinary interest income
at the time it is received or accrued, depending on the U.S. Holder’s method of accounting for U.S.
federal income tax purposes.
A U.S. Holder who uses the cash method of accounting and who receives a payment of stated
interest (including a payment attributable to accrued but unpaid stated interest upon the sale,
exchange, redemption, retirement or other disposition of a Senior Note) will be required to include in
income the U.S. dollar value of the euro payment received (determined based on the spot rate on the
date the payment is received), regardless of whether the payment is in fact converted to U.S. dollars at
that time. A cash basis U.S. Holder will not realize foreign currency exchange gain or loss on the
receipt of stated interest income but may recognize exchange gain or loss attributable to the actual
disposition of the euros received.
A U.S. Holder who uses the accrual method of accounting will accrue stated interest income in
euro and translate that amount into U.S. dollars based on the average spot rate of exchange in effect
for the accrual period or, with respect to an accrual period that spans two taxable years, at the average
spot rate for the partial period within the applicable taxable year. Alternatively, an accrual method U.S.
Holder may elect to translate stated interest income into U.S. dollars at the spot rate on the last day of
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