EFTA Document EFTA01367042

Amendment #4 Page 613 of 868 Air co! mt. Ottenk—T he Group entries rrei ntan restricts cepost accounts for cdredone made from the sale of generated electricity as collateral for related borrow res with the Brazilian Nahone Development Bank (Banco ft/aeons:de Desenvorwmento Eccohnico Bova—SNOBS) Finds si these accounts are nvested in low risk hgaylicesd, shater-term investments that earn interest rates rangirg from 94% to 98%d the COI rate Funds from these accounts are restricted for the payment of ristatments on the related borrowings and for other obligatons related to the operation and rreintenarce of the wind generatvg facilites Banco do Atirceste—Espra marrows a restricted deposit account at Banco do Nordeste a0 Bras! S A eBNB1, whose pupate is to guarantee tne repaymert of borrowings starved for the corstructon cf small hrydroelearic generatng pants Funds in ms account are needed in low risk Garter-lens ewes/merits that earn :merest at 97% of the CD rate Funds are fee:noted its tne fu1 repayment of the related torromrgs, expected to soy in 2026 10. Income and social contribution taxes &co-co.:von 0/Effective Tax Rate—The Group's effective tax rate deers from the amount that would arise using the combined statuary tax rate of 34% applicable for Seven envies as blows 2014 2013 Income before isorre tax and social ortnbut on 36,646 33827 Combined income tax and social contritut on rate 34% 34% Income tax and soca cordribteon at statutory rate (12.460) (106.,688 301: Effect of subedianes taxed under the deemed croft regme 3,752 11404 Allocabon or expense from Perent Utlizaton of unrecorded tax loss carryfaverds 277 Other permanent differences 60 Income and social contnbuuon tax expense Current (t1: 2 437520 411135°3 1) 409.'968 244 Deferred 103 277 Income and social contnbuton lax expense (1.2,417) (9,968) Gwen the deemed peel *Won at the Group's operating voted canpanes, no related tax impacts, current or deferred, have been recorded for the aixabon of expenses from Parent in the combined finance' statements Changes in tax law Law no 12 973—On May 13. 2014. Provisional Measure MP 627 was converted into Law re 12.973. with alterations to some of the orgnei provisons of MP 627. more specifically to those related to the treatment of &Mends interest on own caplet and evaluation d investments at net equity value The Group elected to early adopt such rules beginning calendar year 2014 The effect of these changes had no effect on the combined firenoal datemerts of the Group as dmdends ardror interest on captal were rot greater than hose recorded in accordance wth coot tax accounting methods and criteria effecters as at December 31, 2007 F-293 http://cfdocs.btogo.com:27638/cf/drv7/pub/edgar/2015/07/20/0001193125-15-256461/d78... 7/20/2015 CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0058570 CONFIDENTIAL SDNY_GM_00204754 EFTA01367042