National Grid 2008 Annual Report Download - page 177

BOWNE INTEGRATED TYPESETTING SYSTEM
CRC: 7933
Name: NATIONAL GRID
Date: 17-JUN-2008 03:10:51.35Operator: BNY99999TPhone: [phone]Site: BOWNE OF NEW YORK
Y59930.SUB, DocName: EX-2.B.5.1, Doc: 4, Page: 81
Description: EXH 2(B).5.1
0/1560.00.00.00Y59930BNY
[E/O] EDGAR 2 *Y59930/560/1*
BOWNE INTEGRATED TYPESETTING SYSTEM
CRC: 7933
Name: NATIONAL GRID
Date: 17-JUN-2008 03:10:51.35Operator: BNY99999TPhone: [phone]Site: BOWNE OF NEW YORK
Y59930.SUB, DocName: EX-2.B.5.1, Doc: 4, Page: 81 Description: EXH 2(B).5.1
0/1560.00.00.00Y59930BNY
[E/O] EDGAR 2 *Y59930/560/1*
UNITED KINGDOM TAXATION
The following is a summary of the United Kingdom withholding taxation treatment at the date hereof in relation to
payments of principal and interest in respect of the Instruments. The comments do not deal with other United
Kingdom tax aspects of acquiring, holding or disposing of Instruments. The comments relate only to the position of
persons who are absolute beneficial owners of the Instruments. Prospective Instrumentholders should be aware that
the particular terms of issue of any series of Instruments as specified in the relevant Final Terms may affect the tax
treatment of that and other series of Instruments. The following is a general guide and should be treated with
appropriate caution. Instrumentholders who are in any doubt as to their tax position should consult their professional
advisers. Instrumentholders who may be liable to taxation in jurisdictions other than the United Kingdom in respect of
their acquisition, holding or disposal of the Instruments are particularly advised to consult their professional advisers
as to whether they are so liable (and if so under the laws of which jurisdictions), since the following comments relate
only to certain United Kingdom taxation aspects of payments in respect of the Instruments. In particular,
Instrumentholders should be aware that they may be liable to taxation under the laws of other jurisdictions in relation
to payments in respect of the Instruments even if such payments may be made without withholding or deduction for
or on account of taxation under the laws of the United Kingdom.
81
1 U.K. Withholding Tax on U.K. Source Interest
The Instruments issued by an Issuer which carry a right to interest will constitute “quoted Eurobonds” provided they are and
continue to be listed on a reco
g
nised stock exchan
g
e within the meanin
g
of section 1005 of the Income Tax Act 2007. The
London Stock Exchan
g
e is a reco
g
nised stock exchan
g
e for these purposes. Section 1005 Income Tax Act 2007 provides that
securities will be treated as listed on the London Stock Exchan
g
e if they are admitted to the Official List by the United Kin
g
dom
Listin
g
Authority and are admitted to tradin
g
on the London Stock Exchan
g
e. Whilst the Instruments are and continue to be
quoted Eurobonds, payments of interest on the Instruments may be made without withholdin
g
or deduction for or on account of
United Kingdom income tax.
In all cases fallin
g
outside the exemption described above, interest on the Instruments may fall to be paid under deduction of
United Kin
g
dom income tax at the savin
g
s rate (currently 20 per cent.) subject to such relief as may be available under the
provisions of any applicable double taxation treaty or to any other exemption which may apply. However, this withholdin
g
will
not apply if the relevant interest is paid on Instruments with a maturity date of less than one year from the date of issue and
which are not issued under arran
g
ements the effect of which is to render such Instruments part of a borrowin
g
with a total term
of a year or more.
2 Provision of Information
Instrumentholders should note that where any interest on Instruments or amounts due on redemption of any Instruments which
constitute deeply discounted securities as defined in Chapter 8 of Part 4 of the Income Tax (Tradin
g
and Other Income) Act
2005 is paid to them (or to any person actin
g
on their behalf) by the relevant Issuer or any person in the United Kin
g
dom actin
g
on behalf of such Issuer (a “paying agent”), or is received by any person in the United Kin
g
dom actin
g
on behalf of the relevant
Instrumentholder (other than solely by clearing or arranging the clearing of a cheque) (a “collecting agent”), then the relevant
Issuer, the paying agent or the