Common use of PFIC Status Clause in Contracts

PFIC Status. The Company was not a “passive foreign investment company” (“PFIC”) as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended (the “Code”), for its most recently completed taxable year and, based on the Company’s current projected income, assets and activities, the Company does not expect to be classified as a PFIC for any subsequent taxable year.

PFIC Status. The Company was not a “passive foreign investment company” (“PFIC”) as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended (the “Code”), for its most recently completed taxable year and, based on the Company’s current projected income, assets and activities, the Company does not expect to be classified as a PFIC for any subsequent taxable year.

PFIC Status. The Company was not a “passive foreign investment company” (“PFIC”) ), as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended (the “Code”), for its most recently completed taxable year and, based on the Company’s current projected income, assets and activities, the Company does not expect to be classified as a PFIC for any subsequent taxable year.

PFIC Status. The Company believes it was not a “passive foreign investment company” (“PFIC”) as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended (the “Code”)amended, for its most recently completed taxable year and, based on the Company’s current projected income, assets and activities, the Company does not expect to be classified as a PFIC for any subsequent taxable yearin the immediately foreseeable future.

PFIC Status. The Company believes it was not a “passive foreign investment company” (“PFIC”) as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended (the “Code”), for its most recently completed taxable year and, based on the Company’s current projected income, assets and activities, the Company does not expect to be classified as a PFIC for any in the subsequent taxable year.

PFIC Status. The Company was not a “passive foreign investment company” (“PFIC”) as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended (the “Code”)amended, for its most recently completed taxable year and, based on the Company’s current projected income, assets and activities, the Company does not expect to be classified as a PFIC for any subsequent the current taxable year.year or in the foreseeable future;

PFIC Status. The Company believes that it was not a “passive foreign investment company” (a “PFIC”) ), as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended (the “Code”)amended, for its most recently completed taxable year and, based on the current projections regarding the composition of the Company’s current projected income, income and valuation of its assets and activitiesoperations, the Company does not expect to be classified as become a PFIC for any subsequent taxable yearin the foreseeable future.

PFIC Status. The Company was not classified as a “passive foreign investment company” (“PFIC”) as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended (the “Code”)amended, for its most recently completed taxable year and, based on the Company’s current projected income, assets and activities, the Company does not expect intends to be use reasonable efforts to avoid being classified as a PFIC for any subsequent taxable year.

PFIC Status. The Company was not a “passive foreign investment company” (“PFIC”) as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended (the “Code”), for its most recently completed taxable year and, based on the Company’s current projected income, assets and activities, the Company does not expect to believe that it will be classified as a PFIC for any subsequent taxable yearyear for U.S. federal income tax purposes.

PFIC Status. The To the Company’s knowledge, the Company was not a “passive foreign investment company” (“PFIC”) as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended (the “Code”), for its most recently completed taxable year year, and, based on the Company’s current projected income, assets and activities, the Company does not expect to be classified as a PFIC for any subsequent taxable year.

PFIC Status. The Company was not a “passive foreign investment company” (“PFIC”) as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended (the “Code”)amended, for its most recently completed taxable year and, based on the Company’s current projected income, assets and activities, the Company does not expect to be classified as a PFIC for any subsequent taxable year.

PFIC Status. The Based on the composition of the Company’s income and assets, the Company does not believe it was not a “passive foreign investment company” (“PFIC”) as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended (the “Code”)amended, for its most recently completed recent taxable year and, based on the Company’s current projected income, assets and activities, the Company does not expect to be classified as a PFIC one for any subsequent its current taxable yearyear or in the foreseeable future.

PFIC Status. The Company was not a “passive foreign investment company” (“PFIC”) as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended (the “Code”), for its most recently completed taxable year and, based on the Company’s current projected income, assets and activities, the Company does not expect to be classified as a PFIC for any subsequent taxable yearthe foreseeable future.

PFIC Status. The Company believes that it was not a “passive foreign investment company” (“PFIC”) as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended (the “Code”), for its most recently completed taxable year and, based on the Company’s current projected income, assets and activities, the Company does not expect to be classified as a PFIC for any subsequent taxable year.

PFIC Status. The Company was not a “passive foreign investment company” (“PFIC”) as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended (the “Code”), for its most recently completed taxable year and, based on the Company’s current projected income, assets and activities, the Company does not reasonably expect to be classified as a PFIC for any subsequent taxable year.

PFIC Status. The Company believes that it was not a “"passive foreign investment company” " (“a "PFIC”) "), as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended (the “Code”)amended, for its most recently completed taxable year and, based on the current projections regarding the composition of the Company’s current projected income, 's income and valuation of its assets and activitiesoperations, the Company does not expect to be classified as become a PFIC for any subsequent taxable yearin the foreseeable future.

PFIC Status. The Company was not a “passive foreign investment company” (a “PFIC”) ), as defined in Section 1297 of the United States Internal Revenue Code of 1986Code, as amended (the “Code”)amended, for its most recently completed taxable year and, based on the current projections regarding the composition of the Company’s current projected income, income and valuation of its assets and activitiesoperations, the Company does not expect to be classified as become a PFIC for any subsequent in the current taxable yearyear ending December 31, 2014 or in the foreseeable future.

PFIC Status. The Company believes it was not a “passive foreign investment company” company (“"PFIC”") as defined in within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amended (the “Code”)amended, for its most recently completed taxable year and, based on the Company’s 's current projected income, assets and activities, the Company does not expect to be classified as a PFIC for any subsequent taxable year.

PFIC Status. The Company was not a “passive foreign investment company” (“PFIC”) as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended (the “Code”), for its most recently completed taxable the year ended December 31, 2016 and, based on the Company’s current projected income, assets and activities, the Company does not expect to be classified as a PFIC for the year ended December 31, 2017 or any subsequent taxable year.

PFIC Status. The Company was is not a “passive foreign investment company” (“PFIC”) as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended (the “Code”)amended, for its most recently completed taxable year and, based on the Company’s current projected income, assets and activities, the Company does not expect to be classified as a PFIC for any subsequent in its current taxable yearyear or one or more future taxable years.

PFIC Status. The Company was not a “"passive foreign investment company” " (“"PFIC”") as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended (the “Code”), and for its most recently completed taxable year and, based on the Company’s 's current and projected income, assets and activities, the Company does not expect to be classified as a PFIC for any subsequent taxable year.

PFIC Status. The Company was not a “passive foreign investment company” (a “PFIC”) as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended (the “Code”)amended, for its most recently completed taxable year and, based on the Company’s current projected income, assets and activities, the Company does not expect to be classified as a PFIC for 2010 or any subsequent taxable year.

PFIC Status. The Based on the nature of the Company’s income and the estimated value and composition of the Company’s assets, the Company does not believe that it was not a “passive foreign investment company” (“PFIC”) as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended (the “Code”)amended, for its most recently completed taxable year and, based on the Company’s current projected income, assets and activities, the Company does not expect to be classified as a PFIC for any subsequent taxable year.

PFIC Status. The Neither the Company was not nor its predecessors were a “passive foreign investment company” (“PFIC”) as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended (the “Code”)amended, for its most recently completed taxable year and, based on the Company’s current projected income, assets and activities, the Company does not expect to be classified as a PFIC for any subsequent taxable year.

PFIC Status. The Company was [does not a expect to be classified as] “passive foreign investment company” (“PFIC”) as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended (the “Code”)amended, for its most recently completed taxable year and, based on the Company’s current projected income, assets and activities, the Company does not expect intends to be use reasonable efforts to avoid being classified as a PFIC for any subsequent taxable year.

PFIC Status. The Company was not a “passive foreign investment company” (“PFIC”) as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended (the “Code”)amended, for its most recently completed taxable year and, based on the Company’s current projected income, income and assets and activitiesprojections as to the value of the Company’s ordinary shares and ADSs pursuant to this offering, the Company does not expect to be classified as a PFIC for any subsequent its current taxable year.

PFIC Status. The Company was not a “passive foreign investment company” (“PFIC”) as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended (the “Code”), for its most recently completed taxable year and, based on the Company’s current projected income, assets and activities, the Company does not expect to be classified as a PFIC for 2009 or any subsequent taxable year.

PFIC Status. The Company was not a “passive foreign investment company” (“PFIC”) as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended (the “Code”)amended, for federal income tax purposes for its most recently completed taxable year andyear, based on the Company’s current projected income, assets and activities, the Company does not expect to be classified as a PFIC for any subsequent its current taxable yearyear or in the foreseeable future.

PFIC Status. The Company was not a “passive foreign investment company” (“PFIC”) as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended (the “Code”), for its most recently completed taxable year and, based on the Company’s 's current projected income, assets and activities, the Company does not expect to be classified as a PFIC for any subsequent taxable year.

PFIC Status. The To the Company’s knowledge, the Company was not classified as a “passive foreign investment company” (“PFIC”) as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended (the “Code”)amended, for its most recently completed taxable year and, based on the Company’s current projected income, assets and activities, the year. The Company does not expect intends to be use its reasonable efforts to avoid being classified as a PFIC for any subsequent taxable year.

PFIC Status. The Company does not believe it was not a “passive foreign investment company” (“PFIC”) as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended (the “Code”)amended, for its most recently completed taxable year and, based on the Company’s current projected income, assets and activities, the Company does not expect to be classified as a PFIC for any subsequent in the current taxable yearyear or in the foreseeable future.

PFIC Status. The Company was not a “passive foreign investment company” (“PFIC”) ), as defined in Section section 1297 of the United States U.S. Internal Revenue Code of 1986, as amended (the “Code”)amended, for its most recently completed taxable the year ended December 31, 2017 and, based on the Company’s current projected income, assets and activities, the Company does not expect to be classified as a PFIC for the year ended December 31, 2018 or any subsequent taxable year.

PFIC Status. The Company was not a “passive foreign investment company” (“PFIC”) as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended (the “Code”), for its most recently completed taxable year and, based on the Company’s current projected income, assets and activities, the Company does not expect to be classified as a PFIC in the current taxable year and for any subsequent taxable yearthe foreseeable future.

PFIC Status. The Company (A) was not a “passive foreign investment company” Passive Foreign Investment Company (“PFIC”) as defined in within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amended (amended, and the “Code”), regulations and published interpretations thereunder for its it most recently completed taxable year andyear, based on (B) does not expect to become a PFIC for the Company’s current projected income, assets taxable year and activities, (C) has no plan or intention to conduct its business in a manner that reasonably could be expected to result in the Company does not expect to be classified as becoming a PFIC for any subsequent taxable yearin the future.

PFIC Status. The Company believes it was not a “passive foreign investment company” company (“PFIC”) as defined in within the meaning of Section 1297 1297(a) of the United States U.S. Internal Revenue Code of 1986, as amended (the “Code”)amended, for its most recently completed taxable the year ending December 31, 2016 and, based on the Company’s current projected income, assets and activities, the Company does not expect to be classified as a PFIC for any subsequent in the current taxable yearyear or in the foreseeable future.

PFIC Status. The To the Company’s knowledge, the Company was not a “passive foreign investment company” (“PFIC”) as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended (the “Code”), for its most recently completed taxable year and, based on the Company’s current projected income, assets and activities, the Company does not currently expect to be classified as a PFIC for any subsequent taxable year.

PFIC Status. The Company was not a “passive foreign investment companyPassive Foreign Investment Company” (“PFIC”) as defined in within the meaning of Section 1297 1297(a) of the United States Internal Revenue Code of 1986, as amended (for the “Code”), for its most recently completed taxable year ended December 31, 2015 and, based on the Company’s current projected income, assets and activities, the Company does not expect to be classified as a PFIC for any subsequent the current taxable yearyear ending December 31, 2016. The Company has no plan or intention to conduct its business in a manner that would be reasonably expected to result in the Company becoming a PFIC in the future under current laws and regulations.

PFIC Status. The Company does not believe it was not a “passive foreign investment company” (“PFIC”) as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended (the “Code”), for its most recently completed taxable year and, based on the Company’s current projected income, assets and activities, the Company does not expect to be classified as a PFIC for any subsequent its current taxable yearyear or in the foreseeable future.

PFIC Status. The Company was not a “passive foreign investment company” (“PFIC”) as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended (the “Code”), for its most recently completed taxable year and, based on the Company’s current projected income, assets and activities, the Company does not expect currently intend to operate its business in such a manner as to be classified as a PFIC for any subsequent taxable year.

PFIC Status. The Company was not a “passive foreign investment company” (a “PFIC”) as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended (the “Code”)amended, for its most recently completed taxable year and, based on the Company’s current projected income, assets and activities, the Company does not expect to be classified as a PFIC for 2008 or any subsequent taxable yearyear in the foreseeable future.

PFIC Status. The Company was not a “passive foreign investment company” (“PFIC”) as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended (the “”Code”), for its most recently completed taxable year and, based on the Company’s current projected income, assets and activities, the Company does not expect to be classified as a PFIC for any subsequent taxable year.

PFIC Status. The Company was is not a “passive foreign investment company” (“PFIC”) as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended (the “Code”)) and the Treasury regulations promulgated thereunder, for its most recently completed taxable year and, and based on the Company’s current projected income, assets and activities, the Company does not expect it to be classified as a PFIC for any subsequent taxable year.

PFIC Status. The Company was not a “passive foreign investment company” (“PFIC”) as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended (the “Code”), for its most recently completed taxable year and, based on the Company’s current and projected income, assets and activities, the Company does not expect to be classified as a PFIC in the current taxable year and for any subsequent taxable yearthe foreseeable future.

PFIC Status. The Each of the Company and its Subsidiaries was not a “passive foreign investment company” (“PFIC”) as defined in within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amended (amended, as of the “Code”), for end of its most recently completed recent taxable year and, based on the Company’s current projected incomeexpected composition of its income and the value of its assets, assets and activities, the Company does not expect to be classified as a PFIC for any subsequent the current taxable year.

PFIC Status. The Company was not a “passive foreign investment company” (“PFIC”) ), as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended (the “Code”,” which term, as used herein, includes the regulations and published interpretations thereunder), for its most recently completed taxable year andyear, and based on the Company’s current projected income, assets and activities, the Company does not expect to be classified as a PFIC for any subsequent taxable year.

PFIC Status. The Company was not a “passive foreign investment company” (“PFIC”) as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended (the “Code”), for its most recently completed taxable year and, based on the Company’s current projected income, assets and activitiesactivities and projections as to the value of its ordinary shares and ADSs following the offering of the Offered Securities, the Company does not expect to be classified as a PFIC in the current taxable year and for any subsequent taxable yearthe foreseeable future.

PFIC Status. The Company was not a “passive foreign investment company” (“PFIC”) as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended (the “Code”), for its most recently completed taxable year and, based on the Company’s current projected income, assets and activities, the Company does not expect to be classified as a PFIC for any subsequent its current taxable yearyear or in the foreseeable future.