Ardagh Glass Finance plc - Irish Stock Exchange

acquired the Note (or, in each case, determined on the settlement date if the Senior Notes are traded
on an established securities market and the holder is either a cash basis or an electing accrual basis
holder). Payments received that are attributable to accrued interest will be treated in accordance with
the rules applicable to payments of interest described above. In addition, as discussed above, if Senior
Notes are treated as issued with OID, a U.S. Holder may recognize foreign currency gain or loss with
respect to amounts of previously accrued OID based on the difference between the rate of exchange at
which the OID was included in income in each accrual period while the note is held by the holder and
the applicable rate of exchange at which the holder is required to translate foreign currency at the time
the note matures or is otherwise disposed of. The foreign currency gain or loss will be recognized only
to the extent of the total gain or loss realized by a U.S. Holder on the sale, exchange, retirement,
redemption or other disposition of the Senior Note. Generally, the foreign currency gain or loss will be
U.S. source ordinary income or loss for U.S. foreign tax credit purposes.
Exchange of Foreign Currencies
A U.S. Holder’s tax basis in the euros received as interest on or on the sale or other disposition of
a Senior Note will be the U.S. dollar value of such euros at the spot rate in effect on the date of
receipt of the euros. Any gain or loss recognized by a U.S. Holder on a sale, exchange or other
disposition of the euros will be ordinary income or loss and generally will be U.S. source income or loss
for U.S. foreign tax credit purposes.
Tax Return Disclosure Requirements
Certain U.S. Treasury regulations meant to require the reporting of certain tax shelter transactions
cover transactions generally not regarded as tax shelters, including certain foreign currency transactions
giving rise to losses in excess of a certain minimum amount (e.g., $50,000 in the case of an individual
or trust), such as the receipt or accrual of interest or a sale, exchange, retirement or other taxable
disposition of a foreign currency note or of foreign currency received in respect of a foreign currency
note. Persons considering the purchase of Senior Notes should consult with their own tax advisers to
determine the tax return disclosure obligations, if any, with respect to an investment in the Senior
Notes or the disposition of euros, including any requirement to file IRS Form 8886 (Reportable
Transaction Statement).
Backup Withholding and Information Reporting
Backup withholding and information reporting requirements may apply to certain payments to U.S.
Holders of interest on the Senior Notes and to the proceeds of a sale, exchange or other disposition
(including a retirement or redemption) of a Senior Note. Backup withholding (currently at a rate of
28%) may be required if the U.S. Holder fails (i) to furnish the U.S. Holder’s taxpayer identification
number, (ii) to certify that such U.S. Holder is not subject to backup withholding or (iii) to otherwise
comply with the applicable requirements of the backup withholding rules. Certain U.S. Holders
(including, among others, corporations) are not subject to the backup withholding and information
reporting requirements. Backup withholding is not an additional tax. Any amounts withheld under the
backup withholding rules from a payment to a U.S. Holder generally may be claimed as a credit against
such U.S. Holder’s U.S. federal income tax liability and any excess may result in a refund, provided
that the required information is timely furnished to the IRS.
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