Common use of PFIC Status Clause in Contracts

PFIC Status. Based on the Company’s current income and assets and projections as to the value of its assets and the market value of its Shares, including the current and anticipated valuation of its assets, the Company does not believe it was a Passive Foreign Investment Company (“PFIC”) within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amended, for its most recent taxable year, and does not expect to become a PFIC for its current taxable year or in the foreseeable future.

PFIC Status. Based on the Company’s current income and assets and projections as to the value of its assets and the market value of its SharesSecurities, including the current and anticipated valuation of its assets, the Company does not believe it was a Passive Foreign Investment Company (“PFIC”) within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amended, for its most recent taxable year, and does not expect to become a PFIC for its current taxable year or in the foreseeable future.

PFIC Status. Based on the Company’s current past and projected composition of its income and assets and projections as to the value of its assets assets, and the market value of its Shares, including the current and anticipated valuation of its assets, including goodwill, the Company does not believe it was expect to be a Passive Foreign Investment Company “passive foreign investment company” (“PFIC”) within the meaning of as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended, for its most recent taxable year, and does not expect to become a PFIC for its current taxable year or in the foreseeable future.

PFIC Status. Based on the Company’s current income and assets and projections as to the value of its assets and the market value of its SharesShares immediately following the public offering of its Shares contemplated under this Agreement, including the current and anticipated valuation of its assets, the Company does not believe believes that it was not a Passive Foreign Investment Company (“PFIC”) within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amended, for its most recent taxable year, year and does not expect to become a be PFIC for its current taxable year or in the foreseeable future.

PFIC Status. Based on the Company’s current income and assets and projections as to the value of its assets and the market value of its Ordinary Shares, including the current and anticipated valuation of its assets, the Company does not believe it was a Passive Foreign Investment Company (“PFIC”) within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amended, for its most recent taxable year, and does not expect to become a PFIC for its current taxable year or in the foreseeable future.

PFIC Status. Based on the Company’s current income and assets and projections as to the value expected income, valuation of its assets and its election to treat certain of the market value of its Shares, including the current and anticipated valuation of its assetsCompany’s subsidiaries as disregarded entities for U.S. federal income tax purposes, the Company does not believe it was presently expect to be a Passive Foreign Investment Company (“PFIC”) within the meaning of as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended, for its most recent taxable year, and does not expect to become a PFIC for its the current taxable year or in the foreseeable future. The Company intends to use its reasonable efforts to avoid being classified as a PFIC for all subsequent taxable years.

PFIC Status. Based on the Company’s current income and assets and projections as to the value of its assets and the market value of its American Depositary Shares, including the current and anticipated valuation of its assets, the Company does not believe believes that it was not a Passive Foreign Investment Company (“PFIC”) within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amended, for its most recent taxable year, year and does not expect to become be a PFIC for its current taxable year or in the foreseeable future.

PFIC Status. Based on the Company’s current past and projected composition of its income and assets and projections as to the value of its assets assets, and the market value of its Shares, including the current and anticipated valuation of its assets, including goodwill, the Company does not believe it was expect to be a Passive Foreign Investment Company (“PFIC”) within the meaning of passive foreign investment company” as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended, for its most recent taxable year, and does not expect to become a PFIC for its current taxable year or in the foreseeable future.

PFIC Status. Based on the Company’s current income and assets anticipated operations and projections as to the value composition of its assets earnings and the market value of its Sharesassets, including the current and anticipated expected valuation of its assets, the Company does was not believe it was a Passive Foreign Investment Company (“PFIC”) within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amended, for its most recent the taxable yearyear ended December 31, 2018 and does not expect to become a PFIC for in its current taxable year year; and the Company has no plans or intentions to become a PFIC in the foreseeable future.

PFIC Status. Based on the Company’s current income and assets and projections as to the value of its assets and the market value of its Firm Shares, including the current and anticipated valuation of its assets, the Company does not believe it was a Passive Foreign Investment Company (“PFIC”) within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amended, for its most recent taxable year, and does not expect to become a PFIC for its current taxable year or in the foreseeable future.

PFIC Status. Based on the Company’s current past and projected composition of its income and assets and projections as to the value of its assets assets, and the market value of its Shares, including the current and anticipated valuation of its assets, including goodwill, the Company does not believe it was currently expect to be a Passive Foreign Investment Company “passive foreign investment company” (“PFIC”) within the meaning of as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended, for its most recent current taxable year, and does not expect to become a PFIC for its current taxable year or in the foreseeable future.

PFIC Status. Based on the Company’s current income and assets and projections as to the value of its assets and the market value of its SharesOffered Securities immediately following the public offering of its Offered Securities contemplated under this Agreement, including the current and anticipated valuation of its assets, the Company does not believe believes that it was not a Passive Foreign Investment Company (“PFIC”) within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amended, for its most recent taxable year, year and does not expect to become a be PFIC for its current taxable year or in the foreseeable future.

PFIC Status. Based on the Company’s current income and assets and projections as to the value of its assets and the market value of its American Depositary Shares, including the current and anticipated valuation of its assets, the Company does not believe it was expect to be a Passive Foreign Investment Company (“PFIC”) within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amended, for its most recent taxable year, and does not expect to become a PFIC for its current taxable year or in the foreseeable future.

PFIC Status. Based on the Company’s current income and assets and projections as to the value of its assets and the market value of its SharesADSs, including the current and anticipated valuation of its assets, the Company does not believe it was expect to be a Passive Foreign Investment Company (“PFIC”) within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amended, for its most recent taxable year, and does not expect to become a PFIC for its current taxable year or in the foreseeable future.

PFIC Status. Based on the Company’s current and expected income and assets and projections as to the value of its assets and the market value of its American Depositary Shares, including the current and anticipated valuation of its assets, the Company does not believe it was expect to be a Passive Foreign Investment Company (“PFIC”) within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amended, for its most recent taxable year, and does not expect to become a PFIC for its current taxable year or in the foreseeable future.

PFIC Status. Based on the Company’s current expected composition of income and assets and projections as to the value of its assets and (which is based in part on the market expected value of its American Depositary Shares, including the current and anticipated valuation of its assets), the Company does not believe it was expect to be a Passive Foreign Investment Company passive foreign investment company (“PFIC”) within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amended, for its most recent current taxable year, and does not expect to become a PFIC for its current taxable year or in the foreseeable future.

PFIC Status. Based on the Company’s current income and assets asset and projections as to the value of its assets and the market value of its Shares, including the current and anticipated valuation of its assetsADSs, the Company believes that it was not and does not believe it was expect to be a Passive Foreign Investment Company (“PFIC”) within the meaning of passive foreign investment company” as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended, amended for its most recent taxable year, and does not expect to become a PFIC for its the current taxable year or in the foreseeable future.

PFIC Status. Based on the Company’s current and projected income and assets assets, and projections as to the value of its assets and the market value price of its SharesADSs immediately following this offering, including the current and anticipated valuation of its assets, the Company does not believe believes that it was not a Passive Foreign Investment Company passive foreign investment company (“PFIC”) within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amended, for its most recent taxable year, year and does not expect to become be a PFIC for its current taxable year or in the foreseeable future.

PFIC Status. [Based on the Company’s current composition of income and assets and projections as to the value of its assets and the market value of its American Depositary Shares, including the current and anticipated valuation of its assets, the Company does not believe it was expect to be a Passive Foreign Investment Company passive foreign investment company (“PFIC”) within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amended, for its most recent taxable year, and does not expect to become a PFIC for its current taxable year or in the foreseeable future.]

PFIC Status. Based on the Company’s current income and projected income, assets and projections as to the value activities and taking into account of its assets and the market value of its American Depositary Shares and outstanding Ordinary Shares, including the current and anticipated valuation of its assets, the Company does not believe it was expect to be classified as a Passive Foreign Investment Company (“PFIC”) within the meaning of passive foreign investment company” as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended, for its most recent taxable year, and does not expect to become a PFIC for its current the taxable year or in the foreseeable futureending on December 31, 2014.

PFIC Status. Based on the Company’s current income and assets and projections as to the value of its assets and the market value of its American Depositary Shares, including the current and anticipated valuation of its assets, the Company does not believe believes that it was not a Passive Foreign Investment Company passive foreign investment company (“PFIC”) within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amended, for its most recent taxable year, year and does not expect to become be a PFIC for its current taxable year or in the foreseeable future.

PFIC Status. Based on the Company’s its current income and operations, income, assets and projections certain estimates and projections, including as to the value of its assets and the market value of its Shares, including the current and anticipated valuation relative values of its assets, the Company does believes it will not believe it was be a Passive Foreign Investment Company (“PFIC”) within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amended, for its most recent taxable yearyear ending December 31, 2018, and does not expect to become a PFIC for its current taxable year or in the foreseeable future.

PFIC Status. Based on the Company’s current income and assets and projections as to the value of its assets and the market value of its SharesADSs immediately following this offering, including the current and anticipated valuation of its assets, the Company does not believe believes that it was not a Passive Foreign Investment Company (“PFIC”) within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amended, for its most recent taxable year, year and does not expect to become a be PFIC for its current taxable year or in the foreseeable future.

PFIC Status. Based on the Company’s current and expected income and assets and projections as to the value of its assets and the market value of its American Depositary Shares, including the current and anticipated valuation of its assets, the Company believes that it was not and does not believe it was expect to be a Passive Foreign Investment Company (“PFIC”) within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amended, for its most recent taxable year, year and does not expect to become be a PFIC for its current taxable year or in the foreseeable future.

PFIC Status. Based on the Company’s current and anticipated income and assets and projections as to the value of its assets and the market value of its American Depositary Shares, including the current and anticipated valuation of its assets, the Company does not believe believes that it was not a Passive Foreign Investment Company passive foreign investment company (“PFIC”) within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amendedamended (the “Code”), for its most recent taxable year, and does not expect to become a PFIC for its current taxable year or in the foreseeable future.

PFIC Status. Based on the Company’s current income and projected income, the current value of its assets and projections as to the value of its assets and the market value of its Shares, including the current and anticipated valuation of its assetsADSs, the Company does not believe it was expect to be a Passive Foreign Investment Company (“PFIC”) within the meaning of passive foreign investment company, as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended, for its most recent taxable year, and does not expect to become a PFIC for its current taxable year or in the foreseeable future.

PFIC Status. Based on the current expected composition of the Company’s current income and assets and projections as to the value of its assets and the market value of its Shares, including the current and anticipated valuation of its assets, the Company does not believe it was expect to be a Passive Foreign Investment Company “passive foreign investment company” (“PFIC”) within the meaning of as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amendedamended (the “Code”), for its most recent taxable year, and does not expect to become a PFIC for its current taxable year or in the foreseeable futureyear.

PFIC Status. Based on the Company’s current and projected income and assets and projections as to the value of its assets and the market value of its SharesADSs, including the current and anticipated valuation of its assets, the Company does not believe believes that it was not a Passive Foreign Investment Company passive foreign investment company (“PFIC”) within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amended, for its most recent taxable year, year and does not expect to become be a PFIC for its current taxable year or in the foreseeable future.

PFIC Status. Based on the Company’s current past and projected composition of its income and assets and projections as to the value of its assets assets, and the market value of its Shares, including the current and anticipated valuation of its assets, including goodwill, the Company does not believe it was expect to be a Passive Foreign Investment Company “passive foreign investment company” (“PFIC”) within the meaning of as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended, for its most recent taxable year, and does not expect to become a PFIC for its current taxable year or in the foreseeable future.;

PFIC Status. Based on the current and anticipated value of the Company’s current assets and the composition of its income and assets and the composition of its income and assets and projections as to the value of its assets and the market value of its American Depositary Shares, including the current and anticipated valuation of its assets, the Company does not believe it was expect to be treated as a Passive Foreign Investment Company passive foreign investment company (“PFIC”) within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amended, for its most recent taxable year, and does not expect to become a PFIC for its current taxable year or in the foreseeable future.

PFIC Status. [Based on the past and projected composition of the Company’s current income and assets and projections as to the value of its assets assets, and the market value of its Shares, including the current and anticipated valuation of its assets, including goodwill, the Company does not believe that it was a Passive Foreign Investment Company passive foreign investment company (“PFIC”) within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amendedamended (the “Code”), for its most recent taxable year, year and does not expect to become a PFIC for its in the current taxable year or in the foreseeable future.]