The following summary of certain Estonian tax consequences of the purchase, ownership and disposition of Shares is based upon laws in force and as interpreted by the relevant taxation authorities as of the date of this Offering Circular. Legislative, juridical or administrative changes or interpretations could, however, alter or modify the statements and conclusions set forth herein. Any such changes or interpretations may be retroactive and could affect the tax consequences of a holding of the Shares. This summary does not purport to be a legal opinion or to address all tax aspects that may be relevant to a decision to purchase, own or dispose of the Shares.

Each prospective investor is urged to consult a tax advisor as to the particular tax consequences to such investor of the purchase, ownership and disposition of the Shares, including the applicability and effect of any applicable tax laws or tax treaties, and of pending or proposed changes in applicable tax laws as of the date of this Offering Circular and of any actual changes in applicable tax laws after such date.

Income
The current Estonian Income Tax Law in effect as of January 1, 1994, as amended, treats all income received by individuals and companies on an equal basis subject to income tax at the uniform rate of 26 per cent, except interest income received by individuals, which is subject to 10 per cent withholding tax (Article 7).

Capital Gains
Realised capital gains are regarded for the purposes of the Income Tax Law as income and taxed accordingly (Article 9(1) and Article 10). Shareholders who are not residents of Estonia will be subject to Estonian income tax on capital gains realised on the transfer of shares (Article 10.1.).

Taxation of Dividends
Upon the payment of a dividend by an Estonian company, income tax in the amount of 26/74 of the aggregate amount of the dividend must be paid. This amount is treated as income tax paid in advance, i.e., it is credited against income tax payable by the company at a later time.

Pursuant to Article 9(2).6. of the Income Tax Law dividends paid to Estonian residents are currently not subject to further taxation. Dividends paid by an Estonian company to non-residents, however, are subject to income tax in the amount of 26 per cent (Article 10.2.). The amount of 26/74 of the aggregate amount of dividends paid by the Estonian company as advance tax payment is not regarded as withholding of income tax of the recipient of the dividends. Therefore, pursuant to the requirements of Article 10.2. as discussed above, non-resident recipients of dividends from Estonian companies are required to file their tax reports in that respect with Estonian Tax Board and pay 26 per cent income tax on the amounts received as dividends from the Estonian company.

The Estonian company after having paid an amount equal to 26/74 of the aggregate dividend amount as discussed above has no obligation to make any further withholdings from the amount paid by way of dividend (Article 26(2)).

Stamp Duty
No stamp duty or VAT is applicable upon the transfer of shares in Estonia.