Tabreed 06 Prospectus - London Stock Exchange
Tabreed 06 Prospectus - London Stock Exchange
Tabreed 06 Prospectus - London Stock Exchange
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TAXATION<br />
The following is a general description of certain tax considerations relating to the Certificates. It does<br />
not purport to be a complete analysis of all tax considerations relating to the Certificates. Prospective<br />
purchasers of Certificates should consult their tax advisers as to the consequences under the tax laws of<br />
the country of which they are resident for tax purposes of acquiring, holding and disposing of<br />
Certificates and receiving payments of profit, principal and/or other amounts under the Certificates. This<br />
summary is based upon the law as in effect on the date of this <strong>Prospectus</strong> and is subject to any change<br />
in law that may take effect after such date.<br />
United Kingdom Taxation<br />
The following paragraphs are based on the Issuer’s understanding of United Kingdom law and HM<br />
Revenue & Customs published practice as at the date hereof. They describe the United Kingdom<br />
withholding tax treatment of payments under the Certificates and the extent to which United<br />
Kingdom stamp duty and stamp duty reserve tax would be payable on the issue, transfer and<br />
redemption of the Certificates.<br />
The comments made below do not deal with other United Kingdom tax aspects of acquiring, holding<br />
or disposing of Certificates. Those comments are made on the basis of the following assumptions,<br />
that:<br />
(a) the Issuer is not resident in the United Kingdom for United Kingdom tax purposes;<br />
(b) no register of the Certificates is kept in the United Kingdom by or on behalf of the Issuer; and<br />
(c) no payment to the Certificateholders, including any Periodic Distribution Amount, has a United<br />
Kingdom source for United Kingdom tax purposes.<br />
Those comments relate only to the position of persons who are absolute beneficial owners of the<br />
Certificates.<br />
The following is a general guide and should be treated with appropriate caution. Certificateholders<br />
who are in any doubt as to their tax position should consult their professional advisers.<br />
Certificateholders who may be liable to taxation in jurisdictions other than the United Kingdom in<br />
respect of their acquisition, holding or disposal of the Certificates are particularly advised to consult<br />
their professional advisers as to whether they are so liable (and if so under the laws of which<br />
jurisdictions), since the following comments relate only to certain United Kingdom taxation aspects in<br />
respect of the Certificates. In particular, Certificateholders should be aware that they may be liable to<br />
taxation under the laws of other jurisdictions in relation to payments in respect of the Certificates<br />
even if such payments may be made without withholding or deduction for or on account of taxation<br />
under the laws of the United Kingdom.<br />
United Kingdom Withholding Tax<br />
Periodic Distribution Amounts will be payable without withholding or deduction for or on account of<br />
United Kingdom tax.<br />
Information Reporting<br />
Certificateholders who are individuals may wish to note that where any Periodic Distribution Amount<br />
is paid to them (or to any person acting on their behalf) in respect of the Certificates by the Issuer,<br />
or paid by any person in the United Kingdom acting on behalf of the Issuer (a paying agent), or is<br />
received by any person in the United Kingdom acting on behalf of the relevant Certificateholder<br />
(other than solely by clearing or arranging the clearing of a cheque) (a collecting agent), then the<br />
Issuer or a paying agent (as the case may be) may, in certain cases, be required to supply to HM<br />
Revenue & Customs details of the payment and certain details relating to the Certificateholder<br />
(including the Certificateholder’s name and address). These provisions will apply whether or not the<br />
payment has been paid subject to withholding or deduction for or on account of United Kingdom<br />
income tax and whether or not the Certificateholder is resident in the United Kingdom for United<br />
Kingdom tax purposes. Where the Certificateholder is not so resident, the details provided to HM<br />
Revenue & Customs may, in certain cases, be passed by HM Revenue & Customs to the tax<br />
authorities of the jurisdiction in which the Certificateholder is resident for taxation purposes.<br />
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