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SAPPI LIMITED

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of gain recognized on a sale or other taxable disposition of our ordinary shares or ADSs, as applicable,<br />

unless:<br />

your gain is effectively connected with a trade or business that you conduct in the United States<br />

(and, if an applicable income tax treaty so requires as a condition for you to be subject to United<br />

States Federal income tax on a net income basis in respect of gain from the sale or other<br />

disposition of our ordinary shares or ADSs, as applicable, such gain is attributable to a permanent<br />

establishment maintained by you in the United States); or<br />

you are an individual and are present in the United States for at least 183 days in the taxable year<br />

of the sale or other disposition, and either:<br />

your gain is attributable to an office or other fixed place of business that you maintain in the<br />

United States; or<br />

you have a tax home in the United States.<br />

If you fail the above test, you generally will be subject to tax in respect of such gain in the same<br />

manner as a United States holder, as described above except as altered by applicable income tax treaty.<br />

Effectively connected gains realized by a non-United States corporation may also, under certain<br />

circumstances, be subject to an additional ‘‘branch profits tax’’ at a rate of 30% or such lower rate as may<br />

be specified by an applicable income tax treaty.<br />

Backup Withholding and Information Reporting<br />

Payments and sale proceeds in respect of our ordinary shares or ADSs, as applicable, which are<br />

made in the United States or by a United States related financial intermediary may be subject to United<br />

States information reporting rules. You will not be subject to ‘‘backup’’ withholding of United States<br />

Federal income tax provided that:<br />

you are an exempt recipient; or<br />

you provide a taxpayer identification number (which, in the case of an individual, is his or her<br />

social security number) and meet other information reporting and certification requirements.<br />

If you are a non-United States holder, you generally are not subject to information reporting and<br />

backup withholding, but you may be required to provide a certification of your non-United States status<br />

in order to establish that you are exempt. You may be subject to information reporting and backup<br />

withholding if you sell your ordinary shares or ADSs through a United States broker and you are not<br />

eligible for an exemption. You may be subject to information reporting, but not backup withholding if you<br />

sell your shares or ADSs through a broker with certain connections with the United States and you are<br />

not eligible for an exemption.<br />

Amounts withheld under the backup withholding rules may be credited against your United States<br />

Federal income tax liability, and you may obtain a refund of any excess amounts withheld under the<br />

backup withholding rules by filing the appropriate claim for refund with the Internal Revenue Service.<br />

Documents on Display<br />

Sappi Limited files periodic reports and other information with the SEC. You may read and copy any<br />

document that Sappi Limited files with the SEC on the SEC’s website, www.sec.gov, or at the SEC’s<br />

public reference room at 100 F Street, N.E., Washington, D.C. 20549. Please call the SEC at<br />

1-800-731-0330 (in the United States) or at +1 202 942 8088 (outside the United States) for further<br />

information on the operation of its public reference room.<br />

The documents concerning Sappi Limited referred to in this Annual Report may also be inspected at<br />

the registered office of Sappi Limited at 48 Ameshoff Street, Braamfontein, Johannesburg, Republic of<br />

South Africa.<br />

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