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Share Name | Share Symbol | Market | Type | Share ISIN | Share Description |
---|---|---|---|---|---|
Bnp Energy(2) | LSE:EBMB | London | Ordinary Share | GB00B0ZNS989 | RED PART SHS NPV |
Price Change | % Change | Share Price | Bid Price | Offer Price | High Price | Low Price | Open Price | Shares Traded | Last Trade | |
---|---|---|---|---|---|---|---|---|---|---|
0.00 | 0.00% | 165.00 | 0.00 | 01:00:00 |
Industry Sector | Turnover | Profit | EPS - Basic | PE Ratio | Market Cap |
---|---|---|---|---|---|
0 | 0 | N/A | 0 |
TIDMEBMB TIDMERS TIDMBAP TIDMUSH RNS Number : 6111D Harewood Structured Investment PCC 04 December 2009 Notice to holders of preference shares issued by Harewood Structured Investment PCC Limited (the "Company") This notice is for the attention of holders of preference shares issued by the following cells of the Company: the Enhanced Global Asset Allocation cell, the BNP Paribas FTSE Summit cell, the BNP Paribas Energy - Base Metals Secure Growth cell, the BNP Paribas UK High Income cell, the BNP Paribas Energy - Base Metals (2) cell, the BNP Paribas European Shield cell, the BNP Paribas Absolute Progression cell, the US High Income cell, the Euro High Income cell, the BNP Paribas Agrinvest cell, the Enhanced Property Recovery cell, the Energy - Base Metals (3) cell, the Enhanced Income cell, the BNP Paribas COMAC cell, the US Enhanced Income cell and the UK Enhanced Income cell (together the "affected cells"). The Offshore Funds (Tax) Regulations 2009 (the "Regulations") came into force on 1st December 2009 and introduced a new regime for the United Kingdom tax treatment of Offshore Funds (as such are defined in the Regulations). The Company has been advised that under the previous regime the Company, in respect of all its cells, was not treated as an Offshore Fund. However, it is likely that each series of preference shares issued by the affected cells of Company (the "affected Preference Shares") will each become an Offshore Fund for the purposes of this new regime. Under the new regime, an Offshore Fund (such as a series of affected Preference Shares issued by the Company) may apply to H.M. Revenue & Customs to become a "Reporting Fund". If such an Offshore Fund does not become a Reporting Fund, then that Offshore Fund would be a "Non-Reporting Fund". Broadly, a United Kingdom resident individual holding an interest in a Reporting Fund would be subject to income tax on the income of the fund whether or not that income is distributed to investors, while sales and other disposals of interests in Reporting Funds would be subject to capital gains tax. A United Kingdom resident individual holding an interest in a Non-Reporting Fund" would generally only be subject to income tax on income of the fund which is actually distributed, but gains arising on sales and other disposals of interests in Non-Reporting Funds" would be subject to income tax. The Company intends to apply to H.M. Revenue & Customs for each of its series of affected Preference Shares in respect of an affected cell to become a Reporting Fund with effect from and including the 12 month period commencing on 1st November 2009 and ending on 31st October 2010. Gains arising on sales and other disposals of these Preference Shares by United Kingdom resident individual shareholders (the "Shareholders") after the new regime takes effect will continue to be charged to capital gains tax. Certain Shareholders, such as dealers in securities, may nevertheless be subject to income tax in relation to their Preference Shares on general principles. The Company will be required to compute and report to Shareholders in any affected cell the "Reportable Income" for each period of account of each of its series of Preference Shares. If this "Reportable Income" for a period of account of such an affected cell exceeded the distributions made to Shareholders during that period, Shareholders who acquired such affected Preference Shares on or after 1st December 2009 would be treated as receiving, and would be subject to income tax on, an additional deemed distribution equal to the excess (notwithstanding that no such distribution is in fact made). The Company expects that for each period of account for each of its series of affected Preference Shares, Reportable Income will not exceed distributions made to Shareholders and accordingly Shareholders, while subject to income tax on actual distributions received, should not be subject to income tax on any deemed distributions under the new regime. United Kingdom resident individuals in receipt of dividends from non-United Kingdom companies are generally entitled to a non-payable dividend tax credit equal to one-ninth of the grossed up dividend. However, there is no entitlement to this tax credit if the dividends are paid by an Offshore Fund in circumstances where the Offshore Fund fails to meet a "qualifying investment test". The Company expects that each of its series of dividend paying Preference Shares will meet this test and that Shareholders should generally, subject to their own circumstances, be entitled to a tax credit in respect of dividends paid on such Preference Shares. Dividend paying Preference Shares include those issued by the BNP Paribas UK High Income cell, the US High Income cell, the Euro High Income cell, the Enhanced Income cell, the US Enhanced Income cell and the UK Enhanced Income cell. The purpose of this notice is to provide a summary of the Company's understanding of the effect of the new regime to the United Kingdom tax treatment of Preference Shares for United Kingdom resident individuals. This notice is not intended to be, and should not be construed as, tax advice. The United Kingdom tax treatment of Shareholders depends on their individual circumstances and may be subject to change in the future. Shareholders who may be unsure as to their tax position should seek their own professional advice. For further information contact: BNP Paribas Tel: 0207 595 8056 or E-mail: harewood_solutions@bnpparibas.com Anson Fund Managers Limited Secretary Tel: Guernsey 01481 722260 4 December 2009 END OF ANNOUNCEMENT E&OE - In transmission This information is provided by RNS The company news service from the London Stock Exchange END STRUSVARKKRURAA
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