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Choice of jurisdiction

Royalties may be subject to a low rate of tax in a number of countries, including:

1. •

   offshore jurisdictions, such as Jersey or Guernsey which have low headline rates of tax (0%), or Ireland (12.5%)

2. •

   Malta which has a low effective rate of tax (6% after payment of dividends)

3. •

   many European countries, including Belgium, Netherlands, Cyprus, Ireland and Luxembourg, have special rates of tax applicable to royalties and other income from intellectual property

   These rates may be subject to conditions. For example, the special rate of tax in Belgium only applies to income from registered patents, and in Luxembourg does not apply to intellectual property which has been acquired from a connected party. These conditions should be reviewed carefully.

4. •

   the