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These excerpts taken from the BP 424B5 filed Mar 13, 2009. United Kingdom Taxation
The following is a summary of the material United Kingdom withholding tax consequences at the date hereof in relation to the payment of principal, interest, discount and premium in respect of the debt securities and also contains a summary of the material United Kingdom tax consequences of the ownership and disposition of debt securities. Except where the context otherwise requires, the comments relate only to the position of persons who are absolute beneficial owners of the debt securities and do not deal with the position of certain classes of holders such as dealers. This section is the opinion of the Group General Counsel to BP. We urge prospective investors who are in any doubt as to their tax positions to consult their professional advisers.
United Kingdom Taxation
The following is a summary of the material United Kingdom withholding tax consequences at the date hereof in relation to the payment of principal, STYLE="margin-top:0px;margin-bottom:0px; margin-left:2%">1. Debt securities issued by BP Capital U.K. (U.K. debt securities) STYLE="margin-top:0px;margin-bottom:-6px"> (A) While U.K. debt securities continue to be listed on a recognized stock
(B) Interest on the debt securities may also be paid without (C) In all cases not falling within paragraph (A) or (B) above, subject to relief SIZE="1"> (D) Payments on debt securities that, although not expressed to be interest, fall to be treated as yearly interest for United
FACE="Times New Roman" SIZE="2">(E) Payments, or parts thereof, constituting income in respect of U.K. debt securities have a United Kingdom source and accordingly will be chargeable to United Kingdom tax by direct assessment even if paid 2. Debt Securities issued by BP Capital America and BP Canada (non-U.K. debt securities)
(A) Payments of interest on non-U.K. debt securities may be made
40 Table of Contents(B) Any income in respect of debt securities issued by BP Capital America or BP Canada acting through a These excerpts taken from the BP 424B5 filed Mar 6, 2009. United Kingdom Taxation
The following is a summary of the material United Kingdom withholding tax consequences at the date hereof in relation to the payment of principal, interest, discount and premium in respect of the debt securities and also contains a summary of the material United Kingdom tax consequences of the ownership and disposition of debt securities. Except where the context otherwise requires, the comments relate only to the position of persons who are absolute beneficial owners of the debt securities and do not deal with the position of certain classes of holders such as dealers. This section is the opinion of the Group General Counsel to BP. We urge prospective investors who are in any doubt as to their tax positions to consult their professional advisers.
United Kingdom Taxation
The following is a summary of the material United Kingdom withholding tax consequences at the date hereof in relation to the payment of principal, STYLE="margin-top:0px;margin-bottom:0px; margin-left:2%">1. Debt securities issued by BP Capital U.K. (U.K. debt securities) STYLE="margin-top:0px;margin-bottom:-6px"> (A) While U.K. debt securities continue to be listed on a recognized stock
(B) Interest on the debt securities may also be paid without (C) In all cases not falling within paragraph (A) or (B) above, subject to relief SIZE="1"> (D) Payments on debt securities that, although not expressed to be interest, fall to be treated as yearly interest for United
FACE="Times New Roman" SIZE="2">(E) Payments, or parts thereof, constituting income in respect of U.K. debt securities have a United Kingdom source and accordingly will be chargeable to United Kingdom tax by direct assessment even if paid 2. Debt Securities issued by BP Capital America and BP Canada (non-U.K. debt securities)
(A) Payments of interest on non-U.K. debt securities may be made
40 Table of Contents(B) Any income in respect of debt securities issued by BP Capital America or BP Canada acting through a These excerpts taken from the BP 424B5 filed Nov 5, 2008. United Kingdom Taxation
The following is a summary of the material United Kingdom withholding tax consequences at the date hereof in relation to the payment of principal, interest, discount and premium in respect of the debt securities and also contains a summary of the material United Kingdom tax consequences of the ownership and disposition of debt securities. Except where the context otherwise requires, the comments relate only to the position of persons who are absolute beneficial owners of the debt securities and do not deal with the position of certain classes of holders such as dealers. This section is the opinion of the Group General Counsel to BP. We urge prospective investors who are in any doubt as to their tax positions to consult their professional advisers.
United Kingdom Taxation
The following is a summary of the material United Kingdom withholding tax consequences at the date hereof in relation to the payment of principal, STYLE="margin-top:0px;margin-bottom:0px; margin-left:2%">1. Debt securities issued by BP Capital U.K. (U.K. debt securities) STYLE="margin-top:0px;margin-bottom:-6px"> (A) While U.K. debt securities continue to be listed on a recognized stock
(B) Interest on the debt securities may also be paid without (C) In all cases not falling within paragraph (A) or (B) above, subject to relief SIZE="1"> (D) Payments on debt securities that, although not expressed to be interest, fall to be treated as yearly interest for United
FACE="Times New Roman" SIZE="2">(E) Payments, or parts thereof, constituting income in respect of U.K. debt securities have a United Kingdom source and accordingly will be chargeable to United Kingdom tax by direct assessment even if paid 2. Debt Securities issued by BP Capital America and BP Canada (non-U.K. debt securities)
(A) Payments of interest on non-U.K. debt securities may be made
40 Table of Contents(B) Any income in respect of debt securities issued by BP Capital America or BP Canada acting through a These excerpts taken from the BP 424B5 filed Mar 13, 2008. United Kingdom Taxation
The following is a summary of the material United Kingdom withholding tax consequences at the date hereof in relation to the payment of principal, interest, discount and premium in respect of the debt securities and also contains a summary of the material United Kingdom tax consequences of the ownership and disposition of debt securities. Except where the context otherwise requires, the comments relate only to the position of persons who are absolute beneficial owners of the debt securities and do not deal with the position of certain classes of holders such as dealers. This section is the opinion of the Group General Counsel to BP. We urge prospective investors who are in any doubt as to their tax positions to consult their professional advisers.
United Kingdom Taxation
The following is a summary of the material United Kingdom withholding tax consequences at the date hereof in relation to the payment of principal, STYLE="margin-top:0px;margin-bottom:0px; margin-left:2%">1. Debt securities issued by BP Capital U.K. (U.K. debt securities) STYLE="margin-top:0px;margin-bottom:-6px"> (A) While U.K. debt securities continue to be listed on a recognized stock
(B) Interest on the debt securities may also be paid without (C) In all cases not falling within paragraph (A) or (B) above, subject to relief SIZE="1"> (D) Payments on debt securities that, although not expressed to be interest, fall to be treated as yearly interest for United
FACE="Times New Roman" SIZE="2">(E) Payments, or parts thereof, constituting income in respect of U.K. debt securities have a United Kingdom source and accordingly will be chargeable to United Kingdom tax by direct assessment even if paid 2. Debt Securities issued by BP Capital America and BP Canada (non-U.K. debt securities)
(A) Payments of interest on non-U.K. debt securities may be made
40 Table of Contents(B) Any income in respect of debt securities issued by BP Capital America or BP Canada acting through a This excerpt taken from the BP 20-F filed Jun 13, 2006. United Kingdom Taxation A US holder may be liable for both United Kingdom and United States tax in respect of a gain on the disposal of ordinary shares or ADSs if the US holder is (i) a citizen of the United States resident or ordinarily resident in the United Kingdom, (ii) a United States domestic corporation resident in the United Kingdom by reason of its business being managed or controlled in the United Kingdom or (iii) a citizen of the United States or a corporation that carries on a trade or profession or vocation in the United Kingdom through a branch or agency or, in respect of corporations for accounting periods beginning on or after January 1, 2003, through a permanent establishment, and that have used, held, or acquired the ordinary shares or ADSs for the purposes of such trade, profession or vocation of such branch, agency or permanent establishment. However, subject to applicable limitations and provisions of the Old Treaty, such persons may be entitled to a tax credit against their United States federal income tax liability for the amount of United Kingdom capital gains tax or UK corporation tax on chargeable gains (as the case may be) which is paid in respect of such gain. Under the New Treaty, capital gains on dispositions of ordinary shares or ADSs generally will be subject to tax only in the jurisdiction of residence of the relevant holder as determined under both the laws of the United Kingdom and the United States and as required by the terms of the New Treaty. Under the New Treaty, individuals who are residents of either the United Kingdom or the United States and who have been residents of the other jurisdiction (the United States or the United Kingdom, as the case may be) at any time during the six years immediately preceding the relevant disposal of ordinary shares or ADSs may be subject to tax with respect to capital gains arising from a disposition of ordinary shares or ADSs of the Company not only in the jurisdiction of which the holder is resident at the time of the disposition, but also in the other jurisdiction. This excerpt taken from the BP 20-F filed Jun 30, 2005. United Kingdom Taxation A US holder may be liable for both United Kingdom and United States tax in respect of a gain on the disposal of ordinary shares or ADSs if the US holder is (i) a citizen of the United States resident or ordinarily resident in the United Kingdom, (ii) a United States domestic corporation resident in the United Kingdom by reason of its business being managed or controlled in the United Kingdom or (iii) a citizen of the United States or a corporation that carries on a trade or profession or vocation in the United Kingdom through a branch or agency or, in respect of corporations for accounting periods beginning on or after January 1, 2003, through a permanent establishment, and that have used, held, or acquired the ordinary shares or ADSs for the purposes of such trade, profession or vocation of such branch, agency or permanent establishment. However, subject to applicable limitations and provisions of the Old Treaty, such persons may be entitled to a tax credit against their United States federal income tax liability for the amount of United Kingdom capital gains tax or UK corporation tax on chargeable gains (as the case may be) which is paid in respect of such gain. Under the New Treaty, capital gains on dispositions of ordinary shares or ADSs generally will be subject to tax only in the jurisdiction of residence of the relevant holder as determined under both the laws of the United Kingdom and the United States and as required by the terms of the New Treaty. Under the New Treaty, individuals who are residents of either the United Kingdom or the United States and who have been residents of the other jurisdiction (the United States or the United Kingdom, as the case may be) at any time during the six years immediately preceding the relevant disposal of ordinary shares or ADSs may be subject to tax with respect to capital gains arising from a disposition of ordinary shares or ADSs of the Company not only in the jurisdiction of which the holder is resident at the time of the disposition, but also in the other jurisdiction. | EXCERPTS ON THIS PAGE:
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