S.L. 123.74 ст. 2Parent-Subsidiary Directive to have effect.

The Directive of 23 July, 1990 adopted by the Council of the European Communities on the common system of taxation applicable in the case of parent companies and subsidiaries of different Member States (90/435/EEC) as amended up to and in force on the 1st May, 2004 shall have effect in relation to the

Income Tax Acts. As from 18th January 2012, following the repeal of the above-mentioned EU Directive 90/435/EEC, EU Directive 2011/96/EU of 30 November 2011 on the common system of taxation applicable in the case of parent companies and subsidiaries of different Member States shall have effect in relation to the Income Tax Acts. EU Directive 2011/96/EU shall be read in accordance with the correlation table in Annex III of that same Directive. As from 1st January 2016, EU Directive 2014/86/EU of 8th July 2014 amending Directive 2011/96/EU on the common system of taxation applicable in the case of parent companies and subsidiaries of different Member States shall have effect in relation to the Income Tax Acts. As from 31st December 2015, EU Council Directive 2015/ 121/EU of 27 January 2015 amending Directive 2011/96/EU on the common system of taxation applicable in the case of parent companies and subsidiaries of different Member States shall have effect in relation to the Income Tax Acts.