SCHEDULES

SCHEDULE 2U.K.Taxation provisions relating to re-structuring etc

Transfers of property, rights and liabilities by transfer schemesU.K.

4U.K.For the purposes of the Taxation of Chargeable Gains Act 1992 a disposal constituted by a relevant transfer is to be treated in relation to the transferor and transferee as made for a consideration such that no gain or loss accrues to the transferor.