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Interest paid by a French tax resident in jurisdictions that do not cooperate with France in respect of the exchange of certain tax information will be subject to a 50% withholding tax as of March 1, 2010. Such withholding tax is not applicable if the purpose and the effect of such payment are not principally to transfer funds in such jurisdictions; administrative guidelines released on February 18, 2010 provide for safe harbors under which this condition will be deemed to be met with respect to notes that are (i) issued in a public offer, (ii) listed on a financial market or (iii) registered with a central securities depositary such as Clearstream, Euroclear or DTC. The guidelines also confirm that the tax applies based on the location of the payment, not the tax residence of the creditor, and provide guidance on how to determine the location of a payment in case of a chain of payments through intermediaries.