EFTA Document EFTA01366665

Amendment #4 Page 236 of 868 able ig tor an. The San governtnents focus on pornotorg infrastructure development also extend totax policy, which allows solar cower generation companies to claim an exemption from tip ceymem of income tax for to to 10 years within the fiat 15 years of a propeat operations However, a minimum element tax (generally a approximately 20%) calculated based on book polls le stir applicable ri respect at such projects Accelerated tax depreaaton is also available to solar and weld power generating companies South Niko In August 2011, South Africa s Depanment of Energy, or 'SA DOE launched the RE PPP program whch requres renewable energy developers to bid on a tariff level and the Identified s000-economic development objecOves of the SA DCE The REIPPP program contemplates a total of 6,925 MW will be subject to biding, whch are split into meibple being rounds arc ircltdes seven renewable energy technologies with a volume of MW attached to each technology In the first three rounds of REIPPP program the SA DOE res selected a total of 64 renewable energy projects following three tiding rounds of wroth 33 were solar projects and 22 were wind projects. Collectwely these projects represent a combined generatng capacity of approximately 3912 MW. of which apponmately 1.482 MW related to solar projects and 1 994 MW related to wind projects Each bid is evaluated 'oder the REIPPP program based 70% on amours or the proposed tine and 30% an the specified economic development criteria including employment, local content arc management control, ownersnp chanactenstcs socioeconomic spenang and unease enterprise devebpment inaairres The amount of the feed-intend for the particular project is deletinned based on the bidding process Each winning bidder rider the REIPPP ptogram will • enter into a 20-year PPA with Eslarn that creates an obloshon for Eskom to pay the renewable erector project the agreed tanff for power provided be the protect and • enter into a 20-year Inolementabon Agreement with the SA DOE that creates an obligabon for the renewable energy project to satisfy is identified economic development objectives Under the RE PPP program, the Scutt Al ncan government guarantees the payment otagabons of Esacm under the PPAs with renewable energy producers in defred oraimstances This guarantee arrangement, along with the support package adopted by the Manual Treasury on Septenter 14, 2014 has facatated private sector ()eyelet:mem as f nanong sources and imrestors have been Ming to accept scweregn courtry °skintight of Sixth Afnca s railway strong internatonal creel starting weroul requiring polecat ask nuance as word be the case in vrtually every other African junsactren Based on the sovereign guarantee and support package, we believe that Eskern wen to a be nsk &Rake purchaser with a similar credit profile to our otter cueomers Homing Inlyiduals or enbties that develop and operate renewable energy projects in Honduras will tenets from the forkwing tax incentives (I) sales tax for the purchase of equipment, materials and seroces destined or erectly related to the necessary infrastructure for the generation of energy with renewable resources, fie taxes fees tariffs old mport dries, (s) Income tax holday for ton years, and (vi) atone tax wrthrolorg for payments of services or professional fees of foreign nclvodua}s or legal entities for the pertorrnarce of studies, development realation, ergneerog administration and cinstructon, and monitoring ce the energy renewable project 228 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-0058193 CONFIDENTIAL SDNY GM_00204377 EFTA01366665