Qualifying Noteholder

Qualifying Noteholder. A person that is the beneficial owner of Notes and that is, by virtue of the law of a relevant territory, resident for the purposes of tax in the relevant territory and that will not receive any payment pursuant to this Agreement, the Issuing and Paying Agency Agreement, the Notes or the Guarantee in connection with a trade or business which is carried on by such person through a branch or agency in Ireland. For these purposes, a Relevant Territory means a Member State of the European Union... (other than Ireland) or a country with which Ireland has entered into a double tax treaty at the time a relevant payment is made View More