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Investor Presentaiton

NON-AUSTRALIAN SECURITYHOLDERS Tax and Securities Regulation Distributions - Interest paid on Loan Notes to non-resident holders should be exempt from withholding tax Disposal non-Australian holders should not be subject to Capital Gains Tax on disposal of Spark securities provided they: Have not held an interest of 10% or more in the Stapled Securities for at least 12 months in the 24 months before the disposal, and Do not hold the Securities at any time in connection with carrying on a business at or through a permanent establishment in Australia Eligible Securityholders - No action has been taken to register or qualify the Stapled Securities in any jurisdiction outside Australia or New Zealand. Accordingly, under securities laws applicable in each of the relevant European jurisdictions, only certain institutional, professional and qualified investors will be eligible to invest Tax Treaties - Tax treatment of interest, distributions and disposals of Spark securities may also be affected by applicable tax treaties Disclaimer - This is a general high level summary only and not intended to be comprehensive. Investors should consult their tax adviser for advice on the tax implications for them of investing in Spark securities spark infrastructure SPARK INFRASTRUCTURE INVESTOR PRESENTATION - NOVEMBER 2013 44
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