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should consult their tax adviser concerning the U.S. federal income tax consequences to their partnersof the acquisition, ownership and disposition of Notes by the partnership.The summary assumes that the Issuer is not a passive foreign investment company (a “PFIC”) forU.S. federal income tax purposes, which the Issuer believes to be the case. The Issuer believes that itcurrently meets certain requirements regarding its licensing and activities which allow a bank to treatincome from its banking business as non-passive income for purposes of determining its PFIC status.However, the Issuer’s possible status as a PFIC must be determined annually and therefore may besubject to change. If the Issuer were to be a PFIC in any year, materially adverse consequences couldresult for U.S. Holders.The summary is based on the tax laws of the United States, including the Internal Revenue Code of1986, as amended (the “Code”), its legislative history, existing and proposed regulations thereunder,published rulings and court decisions, as well as on the income tax treaty between the United Statesand the Netherlands (the “Treaty”), all as of the date hereof and all subject to change at any time,possibly with retroactive effect.Bearer Notes are not being offered to U.S. Holders. A U.S. Holder who owns a Bearer Note may besubject to limitations under United States income tax laws, including the limitations provided inSections 165(j) and 1287(a) of the Code.THE SUMMARY OF U.S. FEDERAL INCOME TAX CONSEQUENCES SET OUT BELOW ISFOR GENERAL INFORMATION ONLY. PROSPECTIVE PURCHASERS SHOULD CONSULTTHEIR TAX ADVISERS AS TO THE PARTICULAR TAX CONSEQUENCES TO THEM OFOWNING THE NOTES, INCLUDING THEIR ELIGIBILITY FOR THE BENEFITS OF THETREATY, THE APPLICABILITY AND EFFECT OF STATE, LOCAL, FOREIGN AND OTHERTAX LAWS AND POSSIBLE CHANGES IN TAX LAW.4.1 U.S. Federal Income Tax Characterisation of the NotesThe characterization of a Series or Tranche of Notes may be uncertain and will depend on the terms ofthose Notes. The determination of whether an obligation represents debt, equity, or some otherinstrument or interest is based on all the relevant facts and circumstances. There may be no statutory,judicial or administrative authority directly addressing the characterisation of some of the types ofNotes that are anticipated to be issued under the Programme or of instruments similar to these Notes.Depending on the terms of a particular Series or Tranche of Notes, the Notes may not be characterisedas debt for U.S. federal income tax purposes despite the form of the Notes as debt instruments. Forexample, Notes of a Series or Tranche may be more properly characterised as notional principalcontracts, collateralised put options, prepaid forward contracts, or some other type of financialinstrument. Alternatively, the Notes may be characterised as equity, or as representing an undividedproportionate ownership interest in the assets of, and share of the liabilities of the Issuer. Additionalalternative characterisations may also be possible. Further possible characterisations, if applicable,may be discussed in the relevant Final Terms.No rulings will be sought from the U.S. Internal Revenue Service (“IRS”) regarding thecharacterisation of any of the Notes issued hereunder for U.S. federal income tax purposes. Eachholder should consult its own tax adviser about the proper characterisation of the Notes for U.S.federal income tax purposes and consequences to the holder of acquiring, owning or disposing of theNotes.321