II SÉRIE-A — NÚMERO 78 58

A. Governmental Entity. The government of Portugal, any political subdivision of Portugal (which, for the

avoidance of doubt, includes a state, province, county, or municipality), or any wholly owned agency or

instrumentality of Portugal or any one or more of the foregoing (each, a “Portuguese Governmental Entity”). This

category is comprised of the integral parts, controlled entities, and political subdivisions of Portugal.

1. An integral part of Portugal means any person, organization, agency, bureau, fund, instrumentality, or other

body, however designated, that constitutes a governing authority of Portugal. The net earnings of the governing

authority must be credited to its own account or to other accounts of Portugal, with no portion inuring to the benefit

of any private person. An integral part does not include any individual who is a sovereign, official, or administrator

acting in a private or personal capacity.

2. A controlled entity means an Entity that is separate in form from Portugal or that otherwise constitutes a

separate juridical entity, provided that:

a) The Entity is wholly owned and controlled by one or more Portuguese Governmental Entities directly or

through one or more controlled entities;

b) The Entity’s net earnings are credited to its own account or to the accounts of one or more Portuguese

Governmental Entities, with no portion of its income inuring to the benefit of any private person; and

c) The Entity’s assets vest in one or more Portuguese Governmental Entities upon dissolution.

3. Income does not inure to the benefit of private persons if such persons are the intended beneficiaries of a

governmental program, and the program activities are performed for the general public with respect to the

common welfare or relate to the administration of some phase of government. Notwithstanding the foregoing,

however, income is considered to inure to the benefit of private persons if the income is derived from the use of

a governmental entity to conduct a commercial business, such as a commercial banking business, that provides

financial services to private persons.

B. International Organization. Any international organization or wholly owned agency or instrumentality

thereof.This category includes any intergovernmental organization (including a supranational organization) (1)

that is comprised primarily of non-U.S. governments; (2) that has in effect a headquarters agreement with

Portugal; and (3) the income of which does not inure to the benefit of private persons.

C. Central Bank.An institution that is by law or government sanction the principal authority, other than the

government of Portugal itself, issuing instruments intended to circulate as currency. Such an institution may

include an instrumentality that is separate from the government of Portugal, whether or not owned in whole or in

part by Portugal.

II. Funds that Qualify as Exempt Beneficial Owners. The following Entities shall be treated as Non-Reporting

Portuguese Financial Institutions and as exempt beneficial owners for purposes of sections 1471 and 1472 of

the U.S. Internal Revenue Code.

A. Treaty-Qualified Retirement Fund. A fund established in Portugal, provided that the fund is entitled to

benefits under an income tax treaty between Portugal and the United States on income that it derives from

sources within the United States (or would be entitled to such benefits if it derived any such income) as a resident

of Portugal that satisfies any applicable limitation on benefits requirement, and is operated principally to

administer or provide pension or retirement benefits.

B. Broad Participation Retirement Fund. A fund established in Portugal to provide retirement, disability, or

death benefits, or any combination thereof, to beneficiaries that are current or former employees (or persons

designated by such employees) of one or more employers in consideration for services rendered, provided that

the fund:

1. Does not have a single beneficiary with a right to more than five percent of the fund’s assets;

2. Is subject to government regulation and provides annual information reporting about its beneficiaries to the

relevant tax authorities in Portugal; and