1E9Ct5D

The companies listed in the foregoing paragraph shall, necessarily, satisfy the following conditions:i) at least 51% of the capital must be held by Brazilians;ii) at least 2/3 of the employees must be Brazilians, andiii) the majority of the administrators and managers shall be Brazilians, who shall be guaranteedpredominant powers.Rural real property is subject to the Rural Land Tax (ITR), levied pursuant to the respective Tax Table.The rate ranges between 0.03% and 20%, in accordance with the size of the property, its utilizationand the efficiency of its exploitation and is applicable on the “bare land” value, which is construed asthe total worth of the property, minus the value of its buildings, facilities, improvements, permanentand temporary crop cultures, cultivated and improved pastures and planted forests. The respectiverates and other legal provisions concerning the ITR are set forth in IN/SRF (NormativeInstruction/Federal Revenue Department) 256, of 11 December 2002. An increase in the Rural LandTax rate may occur, in accordance with the utilization ratio of the land and efficiency of the property’sexploitation; this increase is a penalization factor, aimed at discouraging the maintenance ofunproductive properties.Moreover, city properties are subject to a land tax levied on plots of land, and to a building tax - forbuildings. In the City of São Paulo, the rates of this tax for 2006 vary between 0.8% and 1.6%, forresidential properties and 1.2% to 1.8% for commercial property and land, calculated on the fairmarket value of the property, as determined by the Local Government Authority.5.2. MortgageA real property may be given in mortgage as security for the debts or obligations of its owner or ofthird parties. The mortgaged property is subject, by a real relationship, to the performance of theobligation.5.3. Deed of Trust Form of Mortgage (“Alienação Fiduciária”)Law 9,514, of 20 November 1997, which disciplines the Real Estate Financing system, instituted thedeed of trust form of mortgage (“alienação fiduciária”) of real property. Prior to this law, this guarantywas only permitted to finance the purchase of movables. As in a mortgage, the assets given in“alienação fiduciária” are subject, by real relationship, to the performance of the obligation.30