Dit prospectus is gemaakt voor de uitgifte van dit product en ... - Iex

Pursuant to the Luxembourg law of 23 December 2005 as amended by the law of 17 July 2008,Luxembourg resident individuals, acting in the course of their private wealth, can opt to self-declareand pay a 10 per cent. tax on interest payments made after 31 December 2007 by paying agents(defined in the same way as in the Savings Directive) located in an EC Member State other thanLuxembourg, a member state of the European Economic Area other than an EC Member State or in aState or territory which has concluded an international agreement directly related to the SavingsDirective.Such withholding tax will be in full discharge of income tax if the beneficial owner is an individualacting in the course of the management of his or her private wealth.4. United States Federal Income TaxationTO ENSURE COMPLIANCE WITH TREASURY DEPARTMENT CIRCULAR 230, HOLDERSARE HEREBY NOTIFIED THAT: (A) ANY DISCUSSION OF FEDERAL TAX ISSUES IN THISOFFERING CIRCULAR IS NOT INTENDED OR WRITTEN TO BE RELIED UPON, ANDCANNOT BE RELIED UPON, BY HOLDERS FOR THE PURPOSE OF AVOIDING PENALTIESTHAT MAY BE IMPOSED ON HOLDERS UNDER THE INTERNAL REVENUE CODE; (B)SUCH DISCUSSION IS INCLUDED HEREIN BY THE ISSUER IN CONNECTION WITH THEPROMOTION OR MARKETING (WITHIN THE MEANING OF CIRCULAR 230) BY THEISSUER OF THE TRANSACTIONS OR MATTERS ADDRESSED HEREIN; AND (C) HOLDERSSHOULD SEEK ADVICE BASED ON THEIR PARTICULAR CIRCUMSTANCES FROM ANINDEPENDENT TAX ADVISER.The following is a summary of certain material U.S. federal income tax consequences of theacquisition, ownership and disposition of Notes by a U.S. Holder (as defined below). This summarydoes not address the material U.S. federal income tax consequences of every type of Note which maybe issued under the Programme, and the relevant Final Terms may contain additional or modifieddisclosure concerning the material U.S. federal income tax consequences relevant to such type ofNote, as appropriate. This summary deals only with purchasers of Notes that are U.S. Holders and thatwill hold the Notes as capital assets. The discussion does not cover all aspects of U.S. federal incometaxation that may be relevant to, or the actual tax effect that any of the matters described herein willhave on, the acquisition, ownership or disposition of Notes by particular investors, and does notaddress state, local, foreign or other tax laws. In particular, this summary does not address taxconsiderations applicable to investors that own (directly or indirectly) 10 per cent. or more of thevoting stock of the Issuer, nor does this summary discuss all of the tax considerations that may berelevant to certain types of investors subject to special treatment under the U.S. federal income taxlaws (such as financial institutions, insurance companies, investors liable for the alternative minimumtax, individual retirement accounts and other tax-deferred accounts, tax-exempt organisations, dealersin securities or currencies, investors that will hold the Notes as part of straddles, hedging transactionsor conversion transactions for U.S. federal income tax purposes or investors whose functionalcurrency is not the U.S. dollar).As used herein, the term “U.S. Holder” means a beneficial owner of Notes that is, for U.S. federalincome tax purposes, (i) an individual citizen or resident of the United States, (ii) a corporationcreated or organised under the laws of the United States or any State thereof, (iii) an estate the incomeof which is subject to U.S. federal income tax without regard to its source or (iv) a trust if a courtwithin the United States is able to exercise primary supervision over the administration of the trustand one or more U.S. persons has the authority to control all substantial decisions of the trust, or thetrust has elected to be treated as a domestic trust for U.S. federal income tax purposes.The U.S. federal income tax treatment of a partner in a partnership that holds Notes will depend on thestatus of the partner and the activities of the partnership. Prospective purchasers that are partnerships320