billchoa/3036384256-COMP7607-data huggingface dataset:
user: Please translate the following sentence from English to Chinese: (C) an assignment by way of first fixed security of all of the Issuer’s rights, title and interest in, to and under any of its bank accounts in respect of the Notes and the debts represented thereby (but, in the case of an Issuer incorporated in the Cayman Islands, excluding, for the avoidance of doubt, the Issuer’s bank accounts in the Cayman Islands or elsewhere containing the paid up ordinary share capital and any transaction fees of the Issuer and any interest accrued thereon, in each case);

assistant: (C) 就票據及其中所代表的債項，透過第一固定抵押出讓在任何其銀行賬戶中、就任何其銀行賬戶或根據任何其銀行賬戶的所有發行人權利、所有權及權益（但如在發行人在開曼羣島註冊成立的情況下，不包括，爲清楚起見發行人在任何情況下於開曼羣島或其他地方開立，存有發行人的繳足款普通股本及任何交易費用及其中任何累計利息的銀行賬戶）；
user: Please translate the following sentence from English to Chinese: n the minimum switching amount is currently HKD800/ USD100/EUR100 per switch.

assistant: n 現時每次轉換的最低轉換金額爲800港元/100美元/ 100歐羅。
user: Please translate the following sentence from English to Chinese: Unless otherwise specified, defined terms used herein bear the meanings attributed to them in the Prospectus. References to the singular include the plural and vice versa.

assistant: 除另有指明者外，本文件所用詞彙與章程所賦予者具有相同涵義。 表示單數的詞彙包含複數涵義，反之亦然。
user: Please translate the following sentence from English to Chinese: The number of shares authorized to be repurchased in the open market is reduced by the actual number of Employee Offset Shares (as defined below) received.

assistant: 獲授權將於公開市場上購回的股份數目將會扣除實際收到的僱員抵銷股份（定義見下文）。
user: Please translate the following sentence from English to Chinese: All transactions carried out by or on behalf of the scheme must be at arm’s length and executed on the best available terms.

assistant: 由計劃進行或代表計劃進行的所有交易必須以公平交易基準磋商進行及以最佳可得條款執行。
user: Please translate the following sentence from English to Chinese: * For the purposes of this sub-fund, Dealing Day means any Business Day (other than days during a period of suspension of dealing in Shares) and which is also a day where UCITS and/or other Eligible UCIs in which the sub-fund is materially invested are open for normal trading and stock exchanges and Regulated Markets in countries where the sub-fund is materially invested are open for normal trading.

assistant: * 就本附屬基金而言，交易日指任何營業日（股份暫停交易期間的日子除外）且亦是本附屬基金大量投資所在的 UCITS 及∕或其他合資格 UCIs 進行正常交易以及本附屬基金大量投資所在的國家的證券交易所及受監管市場開門進行正常交易的日子。
user: Please translate the following sentence from English to Chinese: Risks associated with convertible bonds – Convertible bonds are a hybrid between debt and equity, permitting holders to convert into shares in the company issuing the bond at a specified future date.

assistant: 與可換股債券相關的風險－可換股債券爲債券與股票的組合，准許其持有人於指定的未來日期將債券轉換爲發行債券的公司之股份。
user: Please translate the following sentence from English to Chinese: Sub-funds investing in high-yield bonds present a higher than average risk due to the greater fluctuation of their currency or the quality of the issuer.

assistant: 投資於高收益債券的子基金可能因其貨幣波幅較大或發行人的質素而產生高於平均的風險。
user: Please translate the following sentence from English to Chinese: Return on an investment in Notes will be affected by charges incurred by investors The Issue Prospectus in respect of an issue of Notes will describe the interest, principal and other applicable payments which may be made under the relevant Notes.

assistant: 投資債券的回報將受投資者須支付的開支所影響 有關發行債券的發行章程，將提述根據有關債券須支付的利息、本金及其他適用款項。
user: Please translate the following sentence from English to Chinese: No. Because the Issuer may redeem the Notes by delivery of the least performing shares in the basket, you may receive the underlying shares, the market value of which may be worth substantially less than the principal amount of the Note upon maturity.

assistant: 不是。 由於發行人可以交付籃子內表現最落後股票之方式贖回票據，　閣下可能會於到期時收取市價遠低於票據本金之掛鉤股票。
user: Please translate the following sentence from English to Chinese: "Accounting Period" means a period ending on an Accounting Date and commencing from the first day immediately following the Accounting Date of the previous year;

assistant: 「會計期間」指從上一年的會計結算日翌日開始至會計結算日爲止的期間；
user: Please translate the following sentence from English to Chinese: With respect to the 7.4% Notes, the Bank is not obliged to make (i) a payment of interest on any interest payment date unless a dividend is paid on any class of share capital and (ii) a payment of principal until six months after the respective maturity date with respect to such Notes.

assistant: 對於7.4%票據，本銀行無責任(i)在任何付息日支付利息，除非已就任何類別之股東支付股息及(ii)就該等票據於各到期日後六個月支付本金。
user: Please translate the following sentence from English to Chinese: As at 31 December 2009, the process of re-registration has not been completed. However, this registration process does not affect the rights of the Bank of China Limited to these assets.

assistant: 於2009年12月31日，權屬更名手續尚未全部完成，但固定資產權屬更名手續不會影響本行承繼該等資產的權利。
user: Please translate the following sentence from English to Chinese: When these operations concern the use of financial derivative instruments, these conditions and limits shall conform to the provisions laid down in the law.

assistant: 當此等運作涉及金融衍生工具的使用時，此等條件及限制應遵照法律所訂的條文。
user: Please translate the following sentence from English to Chinese: ◼ Objective of the Group The Group’s objective is to finance its activities at the best possible rate under normal conditions of operation, and to ensure it can meet its obligations in the event of a crisis.

assistant: 集團之目標 集團之目標是在正常營運情況下，以最佳利率爲其業務融資，並確保一旦出現危機時有力履行責任。
user: Please translate the following sentence from English to Chinese: When “Multiple Valuation Dates” is specified in the applicable Pricing Supplement, the total number of Valuation Dates shall be equal to the number of Valuation Dates specified in the applicable Pricing Supplement (or, if the number of Valuation Dates is not so specified, five Valuation Dates).

assistant: 當「多個估值日」於適用定價補充文件內有所指明，估值日總數應相等於適用定價補充文件指明的估值日數目（或倘無指明多少個營業日，則爲五個營業日）。
user: Please translate the following sentence from English to Chinese: (2) Modification of Agency Agreement The Issuer shall only permit any modification of, or any waiver or authorisation of any breach or proposed breach of or any failure to comply with, the Agency Agreement, if to do so could not reasonably by expected to be prejudicial to the interests of the Noteholders.

assistant: (2) 修訂代理協議 發行人只可在合理地預期不會損害票據持有人的利益下，容許修訂代理協議，或對代理協議授出任何豁免，或授權違反或擬違反或不遵從代理協議。
user: Please translate the following sentence from English to Chinese: You pay to us a cash amount in the specified currency (which is subject to the minimum initial investment as specified in the term sheet) as the initial investment to acquire investment exposure to gold as the reference asset under this product.

assistant: 閣下以指定貨幣向本行支付一筆現金金額（受限於條款表所指定的最低初始投資額）作爲初始投資額，以參與以黃金作爲本產品項下參考資產的投資。
user: Please translate the following sentence from English to Chinese: In selecting a custodian, the Trustee will generally have regard to the relevant qualifications attained by the custodian for purpose of providing custodial service in the relevant jurisdictions and its business track record.

assistant: 在挑選託管人時，受託人一般將考慮該託管人於有關司法管轄區提供託管服務所得的相關資歷及其業務往績記錄。
user: Please translate the following sentence from English to Chinese: (g) Issuer’s rights as beneficial owner of Collateral:

assistant: (g) 發行人作爲抵押品實益擁有人的權利：
user: Please translate the following sentence from English to Chinese: Model risk is governed through Model Oversight Committee (“MOC”) at the Wholesale Credit and Market Risk (“WCMR”) level.

assistant: 模型風險透過模型監察委員會按企業信貸及市場風險管理層面進行管治。
user: Please translate the following sentence from English to Chinese: Part V

assistant: 第五部份
user: Please translate the following sentence from English to Chinese: As described in Annex 1

assistant: 如附件1所述
user: Please translate the following sentence from English to Chinese: 10. Risk Factors The Global Equity Fund is primarily subject to the risks mentioned below.

assistant: 10. 風險因素 環球股票基金主要受以下風險所影響。
user: Please translate the following sentence from English to Chinese: Trustee The Trustee of the Fund is ICBC (Asia) Trustee Company Limited, which is a registered trust company in Hong Kong.

assistant: 受託人 本基金的受託人是工銀亞洲信託有限公司，爲香港一家註冊信託公司。
user: Please translate the following sentence from English to Chinese: In certain cases, the government owns or controls many companies.

assistant: 在某些情況下，政府擁有或控制衆多公司。
user: Please translate the following sentence from English to Chinese: (3) Utilizing the assets of the Fund to provide benefits in favour of a third party other than the Fund Unitholders.

assistant: （3）利用基金財產爲基金份額持有人以外的第三方牟取利益。
user: Please translate the following sentence from English to Chinese: This includes circumstances in which the Depositary or any of its affiliates or connected persons:

assistant: 這包括存管人或其任何聯繫人士或關連人士於以下的情況：
user: Please translate the following sentence from English to Chinese: Corporate Governance (continued)

assistant: 公司治理（續）
user: Please translate the following sentence from English to Chinese: The Guarantor irrevocably waives all notices and demands whatsoever.

assistant: 擔保人不可撤銷地豁免全部通知及任何其他要求。
user: Please translate the following sentence from English to Chinese: The instrument of transfer of a Share shall be signed by or on behalf of the transferor.

assistant: 股份轉讓表格須經轉讓人或其代表簽署。
user: Please translate the following sentence from English to Chinese: This key facts statement only provides you with the key information about one category of our Basket ELIs that we may issue – Basket ELIs (without Autocall and without Daily Knock-in Feature).

assistant: 本資料概要僅向　閣下提供本行可發行的本行的其中一類籃子股票掛鉤投資－籃子股票掛鉤投資（不設自動贖回及不設每日觸及生效機制）的主要資料。
user: Please translate the following sentence from English to Chinese: (ii) invested in high-quality government securities;

assistant: (ii) 投資於優質政府證券；
user: Please translate the following sentence from English to Chinese: Each of the Trustee and the Manager reserves the right to request such information as is necessary to verify the identity of an applicant and the source of the payment.

assistant: 受託人及基金經理各自保留權利可要求提供任何必要資料，以覈實申請人的身份及付款來源。
user: Please translate the following sentence from English to Chinese: The Manager may not be successful in selecting the best-performing securities or investment techniques.

assistant: 基金經理於挑選表現最佳的證券時或其投資技巧未必成功。
user: Please translate the following sentence from English to Chinese: Please note that the website has not been reviewed by the SFC and may contain information on funds not authorised by the SFC.

assistant: 請注意，網站未經證監會審閱，可能載有關於未獲證監會認可的基金的資料。
user: Please translate the following sentence from English to Chinese: (c) For so long as the ELIs are represented by the Global Certificate held on behalf of CCASS or Euroclear and/or Clearstream, Luxembourg, notice may be delivered to CCASS or Euroclear and/or Clearstream, Luxembourg for communication by them to the holders of the ELIs.

assistant: (c) 於股票掛鉤投資仍由代表中央結算系統或歐洲結算系統及或盧森堡結算系統持有之總額證書代表之情況下，通知可送交至中央結算系統或歐洲結算系統及或盧森堡結算系統以轉交股票掛鉤投資持有人。
user: Please translate the following sentence from English to Chinese: The performance and value of the relevant Fund may potentially be adversely affected by any or all of the above factors, or there may be unintended consequences in addition to the above arising from the potential European crisis that may adversely affect the performance and value of the Fund.

assistant: 有關基金的表現及價值可能受到上述任何或所有因素的不利影響，或在上述因潛在歐洲危機而產生的後果以外，亦可能有某些未有預計的後果，這可能對基金的表現及價值造成不利影響。
user: Please translate the following sentence from English to Chinese: Such suspension may take effect at any time after the notice has been given by the Directors as mentioned above or, where the termination or merger requires the approval of a meeting of holders, after the passing of the relevant resolution.

assistant: 有關暫停將在董事會按上文所述發出通知後隨時生效，或倘終止或合併基金須經股東會議批准，則暫停將在通過有關決議案後隨時生效。
user: Please translate the following sentence from English to Chinese: The interpretation and application of tax laws and other applicable regulations by the relevant authorities may not be as transparent or predictable as compared to the authorities administering similar regimes in other developed jurisdictions.

assistant: 有關機關對稅法及其他適用法規的詮釋和運用，與其他已發展的司法管轄區的機關對同類制度的管理相比，透明度或有所不及，或較難預測。
user: Please translate the following sentence from English to Chinese: 5.4 collective investment schemes established in or outside Luxembourg;

assistant: 5.4 在盧森堡境內或境外設立的集體投資計劃；
user: Please translate the following sentence from English to Chinese: Furthermore, the level of collateralization for these assets did not change as result of this presentational change.

assistant: 此外，該等資產的抵押水平並無因這種呈列方式的變動而出現變動。
user: Please translate the following sentence from English to Chinese: Class "K" Shares are initially offered to fund of funds in Korea and will not be publicly offered in Korea.

assistant: 「K」類股份初步提供予韓國之基金中的基金，將不會在韓國公開發售。
user: Please translate the following sentence from English to Chinese: In certain countries, and for certain types of investments, transaction costs are higher and liquidity is lower than elsewhere. Single Market risk Some Funds may invest in a single region, and as a result are subject to higher concentration risk and potentially greater volatility compared to Funds following a more globally diversified policy.

assistant: 在某些國家及就若干類別的投資而言，相對於其他地方，交易成本可能較高，而流動性則較低。 單一市場風險 部分基金可投資於單一區域，因此比採取較全球多元化政策之基金承受較高的資金集中風險，並且可能承受較高波幅。
user: Please translate the following sentence from English to Chinese: Some of such products involve multiple instruments and cash flow profiles such that it is not possible to predict with certainty the outcome from all market scenarios. Also, the price of such an investment could be contingent on, or highly sensitive to, changes in the underlying components of the structured instrument.

assistant: 部份產品涉及多重工具及不同的現金流量水平，因此無法確實預測在所有市況下的投資結果。 此外，有關投資的價格可能取決於結構性產品的相關成份的變動，或受其高度影響。
user: Please translate the following sentence from English to Chinese: (e) any agency or branch of a foreign entity located in the United States;

assistant: (e) 位於美國的外國實體的任何代理機構或分支機構；
user: Please translate the following sentence from English to Chinese: Transfer from Existing Retirement Schemes If the relevant participating employer has a retirement scheme other than a participating scheme of the Principal CPF, subject to the terms of the constitutive documents governing that retirement scheme, employees’ benefits under that retirement scheme may be transferred to the Principal CPF.

assistant: 從現有退休計劃轉入 倘若相關參與計劃的僱主現有除信安中央公積金的參與計劃以外的退休計劃，根據管限該退休計劃的組成文件條款，僱員在該退休計劃下的福利可能轉入信安中央公積金。
user: Please translate the following sentence from English to Chinese: In cases where an investor invests in the Company through an intermediary investing into the Company in his/her/its own name but on behalf of the investor, it may not always be possible for the investor to exercise certain shareholder rights directly against the Company.

assistant: 如投資者透過中介機構以其本身的名義但代表投資者投資於本公司，則該投資者或許不能一直可以直接對本公司行使若干股東權利。
user: Please translate the following sentence from English to Chinese: The remuneration policy is in line with the business strategy, objectives, values and interests of the Management Company and the Company and of its Shareholders, and includes measures to avoid conflicts of interest.

assistant: 薪酬政策與管理公司以及本公司及其股東的業務策略、目標、價值觀及利益一致，幷包括避免利益衝突的措施。
user: Please translate the following sentence from English to Chinese: Such limitation shall be without prejudice to any claims against the relevant Issuer Credit Enhancer (if any).

assistant: 該限制不會損害對有關發行人額外信貸保證機構（如有）的索償。
user: Please translate the following sentence from English to Chinese: (ii) index-tracking collective investment schemes approved by the Authority;

assistant: (ii)獲管理局覈准的指數掛鉤彙集投資計劃；
user: Please translate the following sentence from English to Chinese: 37. Intangible assets continued

assistant: 37. 無形資產續
user: Please translate the following sentence from English to Chinese: At December 31, 2005, the Group’s total portfolio-based provisions amounted to EUR 948 million.

assistant: 於二零零五年十二月三十一日，集團基於投資組合之撥備總額達 9.48 億歐元。
user: Please translate the following sentence from English to Chinese: or (ii) the application is made through a recognised intermediary.

assistant: 或 (ii) 透過認可中介人提出申請。
user: Please translate the following sentence from English to Chinese: Unlike traditional investments such as mutual funds, whose performance is largely dependent on the direction of the broader market, many alternative investment strategies seek positive returns in any market or economic environment.

assistant: 與傳統投資不一樣，如互惠基金，其表現乃主要取決於更廣闊市場的方向，而許多另類投資策略致力於任何市場或經濟環境的正回報收益。
user: Please translate the following sentence from English to Chinese: Assets of hedge funds are not held in separate custody by any institutions that specifically undertake to protect the investor;

assistant: 對沖基金資產並非由專門承諾保障投資者的任何機構獨立託管；
user: Please translate the following sentence from English to Chinese: Information on the Income Statement

assistant: 收入報表資料
user: Please translate the following sentence from English to Chinese: (xiv) Volatility risk – The value of the Funds’ underlying investments will be affected by economic, political, market, and issuer specific changes.

assistant: (xiv) 波幅風險－該等基金之相關投資之價值可能受經濟、政治、市場及發行人特定變動所影響。
user: Please translate the following sentence from English to Chinese: These liabilities include, without limitation, any management fee, performance fee, trustee fee, any taxes, any borrowings and the amount of any interest and expenses thereon, any other costs or expenses expressly authorised by the Trust Deed, and an appropriate allowance for any contingent liabilities.

assistant: 該等負債包括（但不限於）任何管理費、表現費、信託費、任何稅項、任何借貸及有關的任何利息及支出、信託契據明確授權的任何其他費用或支出，以及就任何或然負債作出的適當撥備。
user: Please translate the following sentence from English to Chinese: The Funds should be taxed at an effective rate of 0% to 3%.

assistant: 該等基金應按0%至3%之實際稅率繳稅。
user: Please translate the following sentence from English to Chinese: Specific terms of the issue will be set out in the applicable term sheet.

assistant: 發行之特定條款將載於適用之條款表。
user: Please translate the following sentence from English to Chinese: The Company records high-yield instruments at fair value. Unrealized gains and losses are recognized currently in the Company’s condensed consolidated statements of income.

assistant: 本公司按公平值爲高收益工具入賬。 未變現收益及虧損現時於本公司之簡明綜合收入報表內確認。
user: Please translate the following sentence from English to Chinese: (ii) paragraphs 10 and 11 of the Third Schedule, on the basis that particulars relating to the issue of shares or debentures by the Guarantor will not impact on the Notes and is therefore irrelevant to an investor under the Notes;

assistant: (ii)附表三第10及11段，基準爲有關擔保人發行股份或債券之詳情不會對債券造成影響，因此與票據投資者並無相關；
user: Please translate the following sentence from English to Chinese: Basis of Presentation The Consolidated Financial Statements are prepared in conformity with U.S. generally accepted accounting principles and include the accounts of Holdings, our subsidiaries, and all other entities in which we have a controlling financial interest or are considered to be the primary beneficiary.

assistant: 呈報基準 綜合財務報表按照美國公認會計原則編制，幷包括控股公司、我們的附屬公司及我們擁有控制財務權益或被視爲主要受益人的所有其他實體的賬目。
user: Please translate the following sentence from English to Chinese: During the initial offer period, Units will be offered at the initial offer price as disclosed in column 3 above.

assistant: 於首次發售期內，基金單位將按上文第3欄內所披露的首次發售價提呈發售。
user: Please translate the following sentence from English to Chinese: The maximum amount of such initial charge is set out in the section headed “Fees and Expenses” on page 10 below. Applications for subscription of Units may also be placed through other authorized fund distributors or through other authorized means as may from time to time specified by the Manager in the Manager’s webpage (www.boci-pru.com.hk).

assistant: 該首次收費的最高金額載於以下第10頁「收費及支出」一節。 認購單位的申請亦可透過其他認可基金分銷商或透過基金經理不時於基金經理網頁(www.boci-pru.com.hk)內指定的其他認可方法辦理。
user: Please translate the following sentence from English to Chinese: (iii) take such other actions as it reasonably believes is required by applicable laws or regulations.

assistant: (iii) 採取其合理認爲適用法律法規所規定的其他行動。
user: Please translate the following sentence from English to Chinese: The Valuation Policy and supporting Standards govern the revaluation of all financial assets and liabilities that are fair value measured, covering both market prices as well as model inputs.

assistant: 估值政策和支援標準監督所有按公平價值計量的金融資產和負債每日的重估事宜，包括市場價格以及模型變數。
user: Please translate the following sentence from English to Chinese:  the likely dividend available on liquidation or bankruptcy;

assistant: - 清盤或破產時可收回的清算分配金額；
user: Please translate the following sentence from English to Chinese: Foreign corporations are also generally subject to a U.S. withholding tax at the rate of 30 per cent. (subject to reduction or exemption under an applicable tax treaty, although no such treaty applies to the Funds) imposed on the gross amount of items of U.S. source interest, dividends, and certain other types of investment income which are not effectively connected with the conduct of a U.S. trade or business.

assistant: 外國法團一般亦須繳納稅率爲30%之美國預扣稅（可根據適用稅務條約而獲得扣減或豁免，惟並無任何適用條約應用於該等基金），其乃按源自美國之利息、股息及若干其他並非與進行美國貿易或業務實際有關之投資收入類型之總額徵收。
user: Please translate the following sentence from English to Chinese: Performance Fee (as a % of the Excess Return) and Target Net Asset Value per Share (see Section 9.4.2)

assistant: 業績表現費（超額回報的百分數）及每股資產淨值目標（參見第 9.4.2 節）
user: Please translate the following sentence from English to Chinese: Various potential and actual conflicts of interest may arise from the overall activities of the Issuer and any of its subsidiaries and affiliates.

assistant: 多項潛在及實際的利益衝突可能因發行人、其任何附屬公司及聯繫人的整體活動而產生。
user: Please translate the following sentence from English to Chinese: Investors will incur currency conversion costs and may suffer losses depending on the exchange rate movements of RMB relative to HK dollars or such other currencies. Also, there can be no assurance that RMB will not be subject to devaluation and any depreciation of RMB could adversely affect the value of the investor’s investment in the Fund.

assistant: 投資者將招致匯兌成本，並可能蒙受損失，視乎人民幣相對於港元或該等其他貨幣的匯率走勢而定。 此外，概不能保證人民幣不會貶值，而人民幣的任何貶值可能對投資者於基金的投資價值造成不利影響。
user: Please translate the following sentence from English to Chinese: The worst performing asset for each of the relevant scheduled trading days will be determined by the same methodology as stated on page 93.

assistant: 每個有關原定交易日的表現最差資產將利用第 93 頁所述的同一方法釐定。
user: Please translate the following sentence from English to Chinese: The foreign current account deficit is likely to shrink marginally, at best, as business wanes, leaving the US economy dependent on foreign capital inflows.

assistant: 隨著貿易萎縮，外貿經常帳赤字很可能輕微下降，使美國經濟需依靠外國資金流入。
user: Please translate the following sentence from English to Chinese: In particular, based on established remuneration policies, no employee of the Management Company is paid based on the investment performance of the Fund.

assistant: 特別是，根據已制定的薪酬政策，概無管理公司的僱員根據本傘子基金的投資表現而獲支付薪酬。
user: Please translate the following sentence from English to Chinese: Where investments are made in non-BlackRock Group funds, they will continue to be subject to the external manager’s approach to paying for external research in each case.

assistant: 在投資於非BlackRock Group基金的情況下，該等基金將繼續奉行外聘經理在各情況下支付外聘研究費用的做法。
user: Please translate the following sentence from English to Chinese: Due to this uncertainty in obtaining the TRC, the manager of the Fund (the “Manager”), based on professional tax advice and having discussed this matter with the Fund’s auditor and trustee, has decided to make a provision for 100% of the Fund’s potential Indian tax at the rate of approximately 17.77% on all realized and unrealized short-term gains (i.e., gains on securities held for less than one year) of Indian securities after 20 August 2017, i.e., the date of expiration of the last TRC, with effect from 26 September 2017.

assistant: 由於未能確定是否取得稅務駐在地證書，本基金的經理人（「經理人」）根據專業稅務意見及與本基金的核數師及信託管理人商討後，已決定自2017年9月 26日起，就本基金於2017年8月20日（即去年的稅務駐在地證書的屆滿日期）後來自印度證券的全部實現及未實現短期增值（即持有少於一年的證券之增值）之潛在印度稅項，按大約17.77%稅率作出100%撥備。