Additional Capital Contributions; Tax Treatment of Additional Capital Contributions. Each Member hereby agrees to make on the Closing Date the additional Capital Contribution to the Company set forth opposite such Member’s name in the column captioned “Additional Capital Contribution” on Schedule I attached hereto. Upon the making of the additional Capital Contributions set forth on Schedule I on the Closing Date, and, in the case of VTEX only, full compliance with the obligations set forth in Section 27(r) of this Agreement, each Member shall receive the number and class of Membership Units set forth opposite such Member’s name in the column captioned “Additional Membership Units” on Schedule I. VTEX agrees that it will take all necessary actions to cause the outstanding US$367,500 intercompany loan from VTEX to VIP to be converted into equity of VIP prior to the Closing Date and that such additional equity of VIP will be included in the share capital of VIP required to be contributed by VTEX to the Company on the Closing Date. In addition, VTEX agrees that it will cause the share certificates, stock powers and other instruments required to effect its additional Capital Contribution set forth on Schedule I to be placed in escrow (together with all share certificates of Viking Petroleum UK Limited held by VIP), with an escrow agent (it being agreed that counsel to the Company may act as escrow agent) and on terms mutually agreed by VTEX and the Company no later than two weeks following the date hereof, in order to facilitate the making of such additional Capital Contribution to the Company on the Closing Date. The Members acknowledge and agree that upon the contribution of VTEX’s additional Capital Contribution required to be made on the Closing Date and compliance in full by VTEX with its obligations set forth in Section 27 (r) of this Agreement, the Capital Account of VTEX shall be equal to US$350,000. VTEX’s additional Capital Contribution required to be made on the Closing Date shall be made pursuant to the contribution agreement in the form attached as Exhibit A hereto, which shall be executed and delivered by the Company and VTEX effective as of the Closing Date. The Members acknowledge that VTEX is required to contribute to the capital of the Company on the Closing Date an equity interest in VIP and that VIP will own at the time of that contribution an equity interest in Viking Petroleum UK Limited (“Viking”). The Members further acknowledge that Viking will own at the time of that contribution 100% of Viking UK Gas Limited (“Viking...
