SUMMARY LIMITED TREATY BENEFITS More than 70% of the aggregate vote and value of all shares is ultimately owned by qualified persons and persons which are resident of an EU, EEA or NAFTA member State With regards to shares ultimately owned by residents of an EU,EEA or NAFTA member State, there is a tax treaty between the State of residence of the recipient and USA The recipient of the income is entitled to all benefits of the previously mentioned treaty The recipient of the income would not qualify for total treaty benefits under the LOB provision in the CH-USA tax treaty if it were applicable Under
these circumstances limited treaty protection is not granted
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