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UBS Investment Loan (UBS Global Access Fund? Classes A, B and C) UBS Investment Loan Term Sheet and Application form Term Sheet Number: 300508 Term Sheet Date: 30 May 2008 Feature Summary Eligible

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Commissioners for Her Majesty's Revenue and Customs Lord Reid will explain the judgment of the court these appeals are concerned with schemes designed to avoid the payment of income tax on bankers bonuses the schemes are intended to take advantage of statutory provisions under which could shortly the award of shares to employees is exempt from tax if the shares are subject to a condition making them liable to forfeiture if some contingency occurs for example a senior executive of a company might be awarded shares subject to a condition that the shares would be forfeited if performance targets were not met in that event no tax is payable on the award of the shares under the schemes the bank's decided to award discretionary bonuses to her employees but rather than paying the bonuses to them directly the banks instead used the amount of a bonuses to pay for redeemable shares in offshore companies set up for the purposes of the schemes the shares were then awarded to the employees in place of the bonuses conditions were attached to the shares making them subject to forfeiture if a contingency occurred to qualify for the tax exemption the appeals are test cases for a number of similar schemes in the UBS case the contingency was a specified rise in the footsie 100 indexes within the next three weeks the contingency was unlikely to occur, and it was also hedged against so that even if it did occur the employees would not lose out significantly in the DB case D be standing for Deutsche Bank the contingency was the employees being dismissed for misconduct or voluntarily resigning within the next six weeks once the exemptions had accrued the shares were redeemable by the employees for cash the central question in the appeals is the conditions attached to the shares fall within the scope of the statutory provision conferring the exemption on a literal interpretation of the statute they do but the question is whether a literal interpretation reflects what Parliament intended the first-tier tribunal held that Parliament could not have intended that the exemption should apply to Arrangements contrived purely in order to obtain the exemption and having no other business or commercial purpose that decision was overturned by the upper tribunal who considered that the schemes met the requirements of a legislation the Court of Appeal agreed with the upper tribunal and noted that Parliament had dealt with tax avoidance elsewhere in the legislation but had made no provision in respect of schemes of this kind the revenue now appealed to a Supreme Court unanimously the Supreme Court allows the appeal the court considers the tax statutes are generally concerned with real-world transactions with real world economic effects where a transaction or an element of a transaction has no real world purpose but is designed purely to avoid tax it can usually be said that to allow the tax treatment to be governed by an element that has no real world purpose of any kind is...

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27 printable term sheet is a document that outlines the terms and conditions of an agreement or transaction.

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The parties involved in the agreement or transaction are required to file the 27 printable term sheet.

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The purpose of the 27 printable term sheet is to clearly define the terms and conditions of an agreement or transaction, ensuring that all parties involved are aware of their rights and obligations.

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The 27 printable term sheet typically includes information such as the names of the parties involved, the terms of the agreement, payment details, and any other relevant information.

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