Extract to table

Under Article 28, a resident of the United States claiming benefits under the Treaty must satisfy one or more of the qualifying tests set forth therein

Corporate and institutional holders — including US pension funds, mutual funds, insurance companies, and other entities — must separately analyze their compliance with the LOB provisions

An important distinction must be drawn at the outset

The W-8BEN and W-8BEN-E forms are relevant for non-US holders of ADSs who must certify their non-US status and claim applicable treaty benefits under the US withholding tax system

Non-US Holders — Form W-8BEN / W-8BEN-E Non-US holders of Halcyon ADSs must provide Form W-8BEN (for individuals) or Form W-8BEN-E (for entities) to Meridian Trust Company, N

(Depositary) → German Sub-Custodian (via Ashgrove Enterprises Banking AG) → Halcyon's Dividend-Paying Bank For the German custodian to apply the treaty rate at source, it must receive adequate documentation establishing that the ultimate beneficial owners of the dividends are treaty-eligible US residents