Common use of Passive Foreign Investment Company Clause in Contracts

Passive Foreign Investment Company. Subject to the qualifications, limitations, exceptions and assumptions set forth in the Preliminary Prospectus and the Prospectus, the Company does not expect to be, for the taxable year ending December 31, 2020 or in the immediately foreseeable future, a passive foreign investment company (a “PFIC”), as defined in section 1297 of the Code.

Passive Foreign Investment Company. Subject to the qualifications, limitations, exceptions and assumptions set forth in the Preliminary Prospectus and the Prospectus, the Company does not expect to be, for the taxable year ending December 31, 2020 2017 or in the immediately foreseeable future, a passive foreign investment company (a “PFIC”), as defined in section 1297 of the CodeInternal Revenue Code of 1986, as amended.

Passive Foreign Investment Company. Subject to the qualifications, limitations, exceptions and assumptions set forth in the Preliminary Prospectus and the Prospectus, the Company does not expect to be, for the taxable year ending December 31, 2020 or in the immediately foreseeable future, believe that it was a passive foreign investment company (a “PFIC”), as defined in section 1297 of the CodeInternal Revenue Code of 1986, as amended, for the year ended December 31, 2017, and the Company does not expect to become a PFIC in the current taxable year or the foreseeable future.

Passive Foreign Investment Company. Subject to the qualifications, limitations, exceptions and assumptions set forth in the Preliminary Prospectus Registration Statement, the Pricing Disclosure Package and the Prospectus, the Company does not expect to beit was treated as, for the taxable year ending December 31, 2020 or in the immediately foreseeable future2019, a passive foreign investment company (a “PFIC”), ) as defined in section Section 1297 of the Code, and does not expect to be a PFIC for the taxable year ending December 31, 2020.

Passive Foreign Investment Company. Subject to the qualifications, limitations, exceptions and assumptions set forth in the Preliminary Prospectus and the Prospectus, Prospectus the Company does not expect to be, for the taxable year ending December 31, 2020 2018 or in the immediately foreseeable future, a passive foreign investment company (a “PFIC”)company, as defined in section Section 1297 of the CodeInternal Revenue Code of 1986, as amended.

Passive Foreign Investment Company. Subject to the qualifications, limitations, exceptions and assumptions set forth in the Preliminary Prospectus and the Prospectus, the Company does not expect to be, for the taxable year ending December 31, 2020 or in the immediately foreseeable future, believe that it was a passive foreign investment company (a “PFIC”)company, as defined in section 1297 of the CodeInternal Revenue Code of 1986, as amended for its most recently completed taxable year and does not expect to be for its current taxable year.

Passive Foreign Investment Company. Subject to the qualifications, limitations, exceptions and assumptions set forth in the Preliminary Prospectus and the ProspectusProspectus and based on the Company’s intended use of the proceeds of the offering of ADSs, the Company does not expect to be, for the taxable year ending December 31, 2020 or in the immediately foreseeable future, believe that it was a passive foreign investment company (a “PFIC”), as defined in section 1297 of the CodeInternal Revenue Code of 1986, as amended, for the taxable year ended December 31, 2013, and does not anticipate being a PFIC for its current taxable year.

Passive Foreign Investment Company. Subject to the qualifications, limitations, exceptions and assumptions set forth in the Preliminary Prospectus and the Prospectus, the Company does not expect to be, for the taxable year ending December 31, 2020 or in the immediately foreseeable future, believe that it was a passive foreign investment company (a “PFIC”), as defined in section 1297 of the CodeInternal Revenue Code of 1986, as amended, for the taxable year ended December 31, 2012, and does not anticipate being a PFIC for its current taxable year.

Passive Foreign Investment Company. Subject to the qualifications, limitations, exceptions and assumptions set forth in the Preliminary Prospectus and the Prospectus, the Company does not expect to be, for the taxable year ending December 31, 2020 or in the immediately foreseeable future, believe that it was a passive foreign investment company (a “PFIC”), as defined in section 1297 of the CodeInternal Revenue Code of 1986, as amended, for its taxable year ending June 30, 2017, and does not currently expect to become a PFIC in the foreseeable future.

Passive Foreign Investment Company. Subject to the qualifications, limitations, exceptions and assumptions set forth in the Preliminary Prospectus Registration Statement and the Prospectus, the Company does not expect to beit was treated as, for the taxable year ending December 31, 2020 or in the immediately foreseeable future2020, a passive foreign investment company (a “PFIC”), ) as defined in section Section 1297 of the Code.

Passive Foreign Investment Company. Subject to the qualifications, limitations, exceptions and assumptions set forth in the Preliminary Prospectus Registration Statement, the Pricing Disclosure Package and the Prospectus, the Company does not expect to beit was treated as, for the taxable year ending December 31, 2020 or in the immediately foreseeable future2017, a passive foreign investment company (a “PFIC”), as defined in section Section 1297 of the Code.