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(i)
register as a taxable person pursuant to the GST Law;
(ii)
charge goods and services tax in Jersey in respect of any supply made by it; or
(iii)
subject to limited exceptions that are not expected to apply to the Issuer, pay goods and services tax in Jersey in
respect of any supply made to it.
Stamp duty
No stamp duty is payable in Jersey on the issue or
inter vivos
transfer of Notes.
Upon the death of a holder of Notes, a grant of probate or letters of administration will be required to transfer the Notes
of the deceased person to the extent that the Notes are considered moveable estate situated in Jersey, except that where
the deceased person was domiciled outside of Jersey at the time of death, the Issuer may (at its discretion) dispense with
this requirement where the value of the deceased’s movable estate in Jersey does not exceed £10,000.
Upon the death of a holder of Notes (and to the extent that the Notes are considered moveable estate situated in Jersey),
Jersey stamp duty will be payable on the registration in Jersey of a grant of probate or letters of administration, which
will be required in order to transfer or otherwise deal with:
(i)
(where the deceased person was domiciled in Jersey at the time of death) the deceased person’s personal estate
wherever situated (including any Notes in the Issuer to the extent that the Notes are considered moveable estate
situated in Jersey) if the net value of such personal estate exceeds £10,000; or
(ii)
(where the deceased person was domiciled outside of Jersey at the time of death) the deceased person’s personal
estate situated in Jersey (including any Notes in the Issuer to the extent that the Notes are considered moveable
estate situated in Jersey) if the net value of such personal estate exceeds £10,000.
The rate or amount of stamp duty payable is:
(i)
(where the net value of the deceased person’s relevant personal estate does not exceed £100,000) 0.50 per cent.
of the net value of the deceased person’s relevant personal estate; or
(ii)
(where the net value of the deceased person’s relevant personal estate exceeds £100,000) £500 for the first
£100,000 plus 0.75 per cent. of the net value of the deceased person’s relevant personal estate which exceeds
£100,000; or
(iii)
(where the net value of the deceased person’s relevant personal estate exceeds £13,360,000) the sum of
£100,000.
In addition, application and other fees may be payable.
EU Savings Directive
Under Council Directive 2003/48/EC on the taxation of savings income, Member States are required to provide to the tax
authorities of other Member States details of certain payments of interest or similar income paid or secured by a person
established in a Member State to or for the benefit of an individual resident in another Member State or certain limited
types of entities established in another Member State.
On 24 March 2014, the Council of the EU adopted a Council Directive amending and broadening the scope of the
requirements described above. Member States are required to apply these new requirements from 1 January 2017. The
changes will expand the range of payments covered by the Directive, in particular to include additional types of income
payable on securities. The Directive will also expand the circumstances in which payments that indirectly benefit an
individual resident in a Member State must be reported. This approach will apply to payments made to or secured for
persons, entities or legal arrangements (including trusts), where certain conditions are satisfied, and may in some cases
apply where the person, entity or arrangement is established or effectively managed outside of the EU.
For a transitional period, Luxembourg and Austria are required (unless during that period they elect otherwise) to operate
a withholding system in relation to such payments. The end of the transitional period is dependent upon the conclusion
of certain other agreements relating to information exchange with certain other countries. The changes referred to above
will broaden the types of payments subject to withholding in those Member States which still operate a withholding
