Tabreed 06 Prospectus - London Stock Exchange

United Kingdom Stamp Duty (‘‘Stamp Duty’’) and Stamp Duty Reserve Tax (‘‘SDRT’’)
No Stamp Duty or SDRT is payable on the issue, transfer or redemption of a Certificate. Any
instrument transferring a Certificate on the sale of the Certificate which is executed in the United
Kingdom or which (if not executed in the United Kingdom) relates to any matter or thing done or to
be done in the United Kingdom will be stampable at 0.5 per cent. of the sale consideration.
EU Savings Directive
Under EC Council Directive 2003/48/EC on the taxation of savings income, Member States are
required to provide to the tax authorities of another Member State details of payments of interest (or
similar income, which may include Periodic Distribution Amounts) paid by a person within its
jurisdiction to an individual resident in that other Member State. However, for a transitional period,
Belgium, Luxembourg and Austria are instead required (unless during that period they elect
otherwise) to operate a withholding system in relation to such payments (the ending as of such
transitional period being dependent upon the conclusion of certain other agreements relating to
information exchange with certain other countries). A number of non-EU countries and territories
including Switzerland have adopted similar measures (a withholding system in the case of Switzerland)
with effect from the same date.
United Arab Emirates Taxation
The following summary of the anticipated tax treatment in the UAE in relation to the payments on
the Certificates is based on the taxation law and practice in force at the date of this document, and
does not constitute legal or tax advice and prospective investors should be aware that the relevant
fiscal rules and practice and their interpretation may change. Prospective investors should consult
their own professional advisers on the implications of subscribing for, buying, holding, selling,
redeeming or disposing of Certificates and the receipt of interest and distributions (whether or not on
a winding-up) with respect to such Certificates under the laws of the jurisdictions in which they may
be liable to taxation.
There is currently in force in the Emirates of Abu Dhabi and Dubai legislation establishing a general
corporate taxation regime (the Abu Dhabi Income Tax Decree 1965 (as amended) and the Dubai
Income Tax Decree 1969 (as amended)). The regime is, however, not enforced save in respect of
companies active in the hydrocarbon industry, some related service industries and branches of foreign
banks operating in the United Arab Emirates. It is not known whether the legislation will or will not
be enforced more generally or within other industry sectors in the future. Under current legislation,
there is no requirement for withholding or deduction for or on account of UAE, Abu Dhabi or
Dubai taxation in respect of payments of interest or principal on debt securities (including Periodic
Distribution Amounts or the Dissolution Amounts in relation to the Certificates).
The Constitution of the UAE specifically reserves to the federal government of the UAE the right to
raise taxes on a federal basis for purposes of funding its budget. It is not known whether this right
will be exercised in the future.
The United Arab Emirates has entered into ‘‘Double Taxation Arrangements’’ with certain other
countries, but these are not extensive in number.
Cayman Islands Taxation
There are no income, corporation, capital gains or other taxes in effect in the Cayman Islands on the
basis of present legislation. The Issuer has applied for and expects to obtain an undertaking from the
governor-in-cabinet of the Cayman Islands, pursuant to the Tax Concessions Law (revised) of the
Cayman Islands, that for a period of 20 years from the date of grant of that undertaking no law
which is enacted in the Cayman Islands imposing any tax to be levied on profits, income, gains or
appreciation shall apply to the Issuer or its operations and, in addition, that no tax to be levied on
profits, income, gains or appreciations which is in the nature of estate duty or inheritance tax shall be
payable on or in respect of the shares, debentures or other obligations (which includes the
Certificates) of the Issuer or by way of the withholding in whole or part of any relevant payment. No
capital or stamp duties are levied in the Cayman Islands on the issue, transfer or redemption of
Certificates. An annual registration fee is payable by the Issuer to the Cayman Islands Registry of
Companies which is calculated by reference to the nominal amount of its authorised capital. At
current rates, this annual registration fee is approximately US$575. The foregoing is based on current
law and practice in the Cayman Islands and this is subject to change therein.
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