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This communication (and any attachments) is directed in confidence and may also be legally privileged. It is intended for the exclusive use of the intended recipient and may not otherwise be distributed, copied or disclosed. If you have received this email in error, please notify us immediately by telephone or by return email and delete this communication (including any attachments) and any copy thereof immediately.

When addressed to our clients, any advice or opinion contained in this email (and any attachments) are subject to the terms and conditions expressed in the relevant governing engagement terms. Any action taken or omitted to be taken in reliance on the contents of this email or its attachments is at your own risk and, to the fullest extent permitted by law, Grant Thornton Malta accepts no responsibility or liability to you.

Whilst we have taken reasonable precautions to ensure that any attachment to this e-mail has been swept for viruses, e-mail communications cannot be guaranteed to be secure or error free as information can, inter alia, be corrupted, intercepted, lost or contain viruses. Grant Thornton Malta does not accept liability for such matter or their consequences. In communicating with you by e-mail you accept these risks.

Please note that communications sent by or to any person through our computer systems may be viewed by other Grant Thornton Malta personnel and agents. Anything in this e-mail (and any attachments) which does not relate to Grant Thornton Malta's official business is neither given nor endorsed by Grant Thornton Malta.

Tax disclaimer
Any advice herein is based on the facts provided to us and on current tax law in Malta including judicial and administrative interpretation.  Tax law is subject to continuous change, at times on a retroactive basis.  Should the facts provided to us be incorrect or incomplete or should the law or its interpretation change, our advice may be inappropriate.  We are not responsible for updating our advice for changes in law or interpretation after the date hereof.

US Revenue Service Circular 230 disclosure
To ensure compliance with requirements imposed by the IRS, we inform you that any tax advice contained in this communication (including any attachments) is not intended or written to be used, or cannot be used, for the purpose of (i) avoiding penalties under the US Internal Revenue Code, or (ii) promoting, marketing or recommending to any other party any matters addressed herein.


Grant Thornton International Limited and the member firms are not a worldwide partnership. Services are delivered independently by the member firms. 'Grant Thornton' refers to the brand under which the Grant Thornton member firms provide assurance, tax and advisory services to their clients and/or refers to one or more member firms, as the context requires.

Our opinion is given in terms of our current engagement letter and is limited to the conclusions specifically set forth herein and is based on the completeness and accuracy of the assumptions, facts and representations made to us. If any of these assumptions, facts and representations is not entirely complete or accurate, it is imperative that we are informed immediately, as the inaccuracy or incompleteness thereof could have a material effect on our conclusions. In rendering our advice, we are relying upon the currently applicable relevant provisions of Maltese law as amended to date (without regard to EU law except to the extent specifically indicated), the regulations made thereunder, and the judicial and administrative interpretations thereof as these are applicable and known to us as at the date hereof. We shall not update our advice for subsequent changes or modifications to the law and regulations or to the judicial and administrative interpretations thereof. We express no opinion on the tax of any jurisdiction other than Malta or on any other matter.

Furthermore, we express no assurance or guarantee that our views will necessarily accord with those of any competent authority in whole or in part. This advice is strictly limited to the matters stated herein and does not apply, by implication or otherwise, to any other matter. This advice is furnished to you on the basis that it is for your sole benefit and use.



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