This document intends to outline the minimum requirements for a tax opinion for being accepted by the directors of the issuer, purchasing or subscribing to the shares in the Target Company, in the context of the issuance of a structured product.

This document is focusing on the underlying investment, i.e. in-between i) the Issuer (of the structured product) being the purchaser or subscriber, ii) the seller of the shares (if applicable), and iii) the Target Company.

The scenarios under review are either i) a direct purchase of shares (i.e. a secondary from a seller or of treasury shares) or ii) a direct subscription of shares (i.e. a primary).