1. 1 Estimate of potential Australian FIF tax (worst case) Average UK financial assets subject to FIF taxation £25,000 Earnings rate 10% pa Deemed income pa £2,500 Personal tax @ top rate of 48½%£1,213 pa Number of years since 1 January 1993 9 Personal tax now due £10,917 Primary penalty @ 75% (flat) for wilful non disclosure £8,188 Interest penalty @ 10% pa £4,072 Estimated Australian back tax and penalties due £23,177 Total Australian back tax per UK Institution per 1,000 policies (likely no. of Australian policyholders) £23,177,000 Plus Australian FIF tax going forward of £1,213 pa, per 1,000 policies at each UK institution £1,213,000

2. 2 Estimate of potential Australian FIF tax (best case) Average UK financial assets subject to FIF taxation £25,000 Earnings rate 10% pa Deemed income pa £2,500 Personal tax @ top rate of 48½% £1,213 pa Number of years since 1 January 1993 9 Personal tax now due £10,917 Primary penalty @ 0% - legislation too complex - Interest penalty @ 10% pa £4,072 Estimated Australian back tax and penalties due £14,989 Total Australian back tax per UK Institution per 1,000 policies (likely no. of Australian policyholders) £14,989,000 Plus Australian FIF tax going forward of £1,213 pa, per 1,000 policies per UK Institution £1,213,000

3. 3 Estimate of potential Australian FIF tax (likely case) Average UK financial assets subject to FIF taxation £25,000 Earnings rate 10% pa Deemed income pa £2,500 Personal tax @ top rate of 48½% £1,213 pa Number of years since 1 January 1993 9 Personal tax now due £10,917 Primary penalty @ 25% (flat) for non disclosure if due to bad advice£2,729 Interest penalty @ 10% pa £4,072 Estimated Australian back tax and penalties due £17,718 Total Australian back tax per UK Institution per 1,000 policies (likely no. of Australian policyholders) £17,718,000 Plus Australian FIF tax going forward of £1,213 pa, per 1,000 policies per UK Institution £1,213,000