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4.3 U.S. Federal Income Tax Treatment of Certain Notes Not Treated as DebtThe following summary may apply to certain Notes that are not treated as debt for U.S. federalincome tax purposes. This summary does not discuss all types of Notes that may not be treated as debtfor U.S. federal income tax purposes. The relevant Final Terms will specify if the discussion belowwill apply to a particular Series or Tranche of Notes. The U.S. federal income tax consequences ofowning Notes that are not treated as debt for U.S. federal income tax purposes and are not describedbelow will be discussed, as appropriate, in the relevant Final Terms.Equity NotesCertain Notes may be treated as equity in the Issuer for U.S. federal income tax purposes. Thefollowing discussion will apply to Notes that are characterised as equity of the Issuer (“EquityNotes”).Distributions on Equity NotesGeneralDistributions paid by the Issuer with respect to Equity Notes out of current or accumulated earningsand profits (as determined for U.S. federal income tax purposes) will generally be taxable to a U.S.Holder as foreign source dividend income, and will not be eligible for the dividends receiveddeduction allowed to corporations. Distributions in excess of current and accumulated earnings andprofits will be treated as a non-taxable return of capital to the extent of the U.S. Holder’s basis in theEquity Notes and thereafter as capital gain. However, the Issuer does not maintain calculations of itsearnings and profits in accordance with U.S. federal income tax accounting principles. U.S. Holdersshould therefore assume that any distribution by the Issuer with respect to Equity Notes will constituteordinary dividend income. U.S. Holders should consult their own tax advisers with respect to theappropriate U.S. federal income tax treatment of any distribution received from the Issuer.For taxable years that begin before 2011, dividends paid by the Issuer will generally be taxable to anon-corporate U.S. Holder at the special reduced rate normally applicable to long-term capital gains,provided the Issuer qualifies for the benefits of the Treaty, which the Issuer believes to be the case. AU.S. Holder will be eligible for this reduced rate only if it has held the Equity Notes for more than 60days during the 121-day period beginning 60 days before the ex-dividend date.Foreign Currency DividendsDividends paid in a foreign currency will be included in income in a U.S. dollar amount calculated byreference to the exchange rate in effect on the day the dividends are received by the U.S. Holder,regardless of whether the foreign currency is converted into U.S. dollars at that time. If dividendsreceived in a foreign currency are converted into U.S. dollars on the day they are received, the U.S.Holder generally will not be required to recognise foreign currency gain or loss in respect of thedividend income.Sale or other Disposition of Equity NotesUpon a sale or other disposition of Equity Notes, a U.S. Holder generally will recognise capital gainor loss for U.S. federal income tax purposes equal to the difference, if any, between the amountrealised on the sale or other disposition and the U.S. Holder’s adjusted tax basis in the Equity Notes.This capital gain or loss will be long-term capital gain or loss if the U.S. Holder’s holding period inthe Equity Notes exceeds one year. However, regardless of a U.S. Holder’s actual holding period, anyloss may be long-term capital loss to the extent the U.S. Holder receives a dividend that qualifies for333