Avocet Mining PLC Prospectus December 2011

c105718pu070 Proof 5: 7.12.11_13:44 B/L Revision:
Temporary non-UK tax resident Shareholders
An individual Shareholder who ceases to be tax resident or ordinarily resident in the UK for a period
of less than five years of assessment and who disposes of Ordinary Shares during that period of
temporary non-residence may be liable to UK capital gains tax in the tax year of assuming UK
residency (subject to available exemptions or reliefs).
Non-UK tax resident Shareholders
A Shareholder who is not resident and, in the case of an individual, not ordinarily resident for tax
purposes in the UK (and is not temporarily non-UK tax resident as described above) will not
generally be liable for UK tax on chargeable gains realised on the sale or other disposal of his or her
Ordinary Shares unless such Ordinary Shares are used, held or acquired in connection with a trade,
profession or vocation carried on in the UK through a branch or agency or, in the case of a
corporate Shareholder, through a permanent establishment. Such Shareholders may be subject to
foreign taxation on any gain under local law subject to the terms of any applicable double tax treaty.
Persons who are not tax resident in the United Kingdom should consult their own tax advisers on
the possible application of such provisions and on what relief or credit may be claimed in the
jurisdiction in which they are tax resident.
(c) Stamp Duty and SDRT
It is expected that no SDRT should be payable on a transfer of a depository receipt within the DnB
NOR Verdipapirservice clearance service in Oslo, on the assumption that DnB NOR
Verdipapirservice has not made an election under section 97A Finance Act 1986. No stamp duty
should be payable provided that any document that effects such a transfer is not executed in the
United Kingdom and that it remains at all subsequent times outside the United Kingdom.
A transfer on the sale of Ordinary Shares held in certificated form will ordinarily be subject to stamp
duty on the instrument of transfer, generally at the rate of 0.5 per cent. of the amount or value of
the consideration rounded up to the nearest £5. The liability to pay stamp duty or SDRT is generally
that of the purchaser or transferee.
Paperless transfers of shares within CREST will be liable to SDRT rather than stamp duty (generally
at a rate of 0.5 per cent. of the consideration) and SDRT on the relevant transactions settled in
CREST or reported through CREST for regulatory purposes will generally be collected by CREST.
The charge is generally borne by the purchaser.
Stamp duty or SDRT is payable at a higher rate of 1.5 per cent when shares are transferred into a
depositary receipt scheme or a clearance service where the shares are held by a third party and can
subsequently be traded free of stamp duty or SDRT.
It should be noted that certain categories of person may not be liable to stamp duty or SDRT and
others may be liable at a higher rate or may, although not primarily liable for tax, be required to
notify and account for SDRT. Special rules, including certain exemptions, may apply to approved
market intermediaries, and professional advice should be sought in such circumstances.
2. Norwegian taxation
Set out below is a summary of certain Norwegian tax matters related to investments in the Company.
The summary is based on Norwegian laws, rules and regulations applicable as of the date of this
Prospectus, which may be subject to any changes in law occurring after such date. Such changes
could possibly be made on a retroactive basis. The summary only addresses Norwegian tax laws. The
summary is of a general nature and does not purport to be a comprehensive description of all the
Norwegian tax considerations that may be relevant for a decision to acquire, own or dispose of
shares in the Company. Shareholders who wish to clarify their own tax situation should consult with
and rely upon their own tax advisers. Shareholders resident in jurisdictions other than Norway and
Shareholders who cease to be resident in Norway for tax purposes (due to domestic tax law or tax
treaty) should consult with and rely upon their own tax advisors with respect to the tax position in
their country of residence and the tax consequences related to ceasing to be resident in Norway for
tax purposes. The Norwegian government has recently proposed certain amendments to Norwegian
tax legislation. The proposed amendments that may have an impact on the taxation of the investment
in the Company are set out below.
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