Barclays, Base Prospectus 2006

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(iii) Application of the tax provisions of the German Investment Tax Act
The application of the German Investment Tax Act (Investmentsteuergesetz) requires the holding of an
interest in an investment fund (Investmentanteile).
According to a tax decree of the German tax administration dated 2 June 2005 (BMF, IV C 1 - S 1980 -
1 - 87/05) concerning the application the German Investment Tax Act in case of foreign investment
funds an interest requires that between the holder and the legal entity owning the foreign fund assets
exists a direct legal relationship which, however, has not to be membership-like relationship.
According to the tax decree a security being issued by a third party and only reflecting the economic
results of a foreign investment fund or several foreign investment funds (e.g. a Note) will not be
regarded as a unit in a foreign investment fund. In certain cases, e.g. if a security provides for a
physical delivery of interests in funds, the Investment Tax Act may apply, in which case investors may
be subject to tax with fictitious profits. Furthermore, following the physical delivery of interests in
entities which qualify as foreign investment funds the holder of such instruments would be subject to
the provisions of the lnvestment Tax Act as well.
(b) Taxation if the Notes are held as business assets (Betriebsvermögen)
In case of tax resident corporations or individual investors holding Notes as business assets
(Betriebsvermögen), capital gains from a disposal or redemption of Notes will be subject to corporate
income tax or income tax, as the case may be, (each plus solidarity surcharge) and trade tax regardless
of whether or not the Notes are sold or redeemed within one year after acquisition.
If instead of a cash-settlement at maturity of a Note, a physical delivery of bonds, shares, interests in
funds takes place, such delivery would be regarded as a taxable sale of the Note and the according
capital gain will be subject to corporate income tax or income tax, as the case may be, (each plus
solidarity surcharge) and trade tax.
Withholding tax and solidarity surcharge thereon are credited as prepayments against the German
personal income tax liability (or corporate income tax liability, as the case may be) and the solidarity
surcharge. If the tax withheld exceeds the respective tax liability, the difference will be refunded to a
tax resident holder of Notes within the tax assessment procedure.
With respect to the application of the Investment Tax Act please see section (a) (iii) above, which
applies analogously in case of investors holding the Notes as business assets.
Non-residents
Persons, who are not tax resident in Germany, are not subject to tax, unless the Notes (i) are held as
business assets of a German permanent establishment (including a permanent representative) which is
maintained by the holder of the Notes or (ii) the income under the Notes is part of taxable German
source income for other reasons.
Inheritance and Gift Tax
No inheritance or gift taxes with respect to any Note will arise under the laws of Germany, if, in the
case of inheritance tax, neither the decedent nor the beneficiary, or, in the case of gift tax, neither the
donor nor the donee, is a resident of Germany and such Note is not attributable to a German trade or
business for which a permanent establishment is maintained, or a permanent representative has been
appointed, in Germany. Exceptions from this rule apply to certain German expatriates.
Other Taxes
No stamp, issue, registration or similar taxes or duties will be payable in Germany in connection with
the issuance, delivery or execution of the Notes. Currently, net assets tax is not levied in Germany.