Smurfit Kappa Italia S p.A., a company incorporated under the laws of Italy, with registered office in vxx Xxxxxxxx Xxxxx n. 12, 20123, Milano, VAT number 02124341203 (the “Company”) AND
U.S. Real Property Holding Corporation The Company is not and has never been a U.S. real property holding corporation within the meaning of Section 897 of the Internal Revenue Code of 1986, as amended, and the Company shall so certify upon Purchaser’s request.