definiens: within the meaning of Section 1221 of the Code(generally, property held for investment purposes ) . This summary is not a complete description of all of the U.S. federal income taxconsequences of the tender of Shares or ADSs, and in particular, may not address U.S. federal income tax consequences applicable topersons subject to special treatment under U.S. federal income tax law, including, for example, brokers, dealers in securities or currencies, traders in securities that elect to use a mark - to - market method of accounting for securities holdings, tax - exempt organizations ( includingprivate foundations ), insurance companies, banks, thrifts and other financial institutions, real estate investment trusts, regulated investmentcompanies, persons liable for the alternative minimum tax, persons that hold an interest in an entity that holds Shares or ADSs, persons thatown, or have owned, directly, indirectly or constructively, 10 % or more ( by vote or value ) of the Company ’s equity, persons that hold Sharesor ADSs as part of a hedge, wash sale, straddle, constructive sale, conversion transaction or other integrated transaction for U.S. federalincome tax purposes, entities treated as partnerships for U.S. federal income tax purposes and holders of interests therein, persons whosefunctional currency is not the U.S. dollar and certain former citizens or long - term residents of the United States, all of whom may be subjectto tax rules that differ significantly from those summarized below . In addition, this summary does not discuss any aspect of any non - U.S.,state, local or estate or gift taxation or the Medicare contribution tax on certain net investment income . Each holder of Shares or ADSs isurged to consult its tax advisor regarding the U.S. federal, state, local and non - U.S. income and other tax consequences of the tender ofShares or ADSs pursuant to the U.S. Offer