Tax Treatment of PLNs

For immediate release 2 December 2003 PANTHEON INTERNATIONAL PARTICIPATIONS PLC TAX TREATMENT OF PARTICIPATING LOAN NOTES The Board of Pantheon International Participations PLC ('PIP' or the 'Company') notes the proposals published by Jupiter Global Green Investment Trust Plc on 21 November for the conversion of its Participating Loan Notes ('PLNs'). In the light of these proposals, the Board wishes to confirm the advice it has received from its professional tax advisers on the tax treatment of PIP in relation to its PLNs. The Board has been advised that no provision for taxation is required in the accounts of the Company to date in relation to its PLNs. The PLN's fall to be taxed under the loan relationships regime. Accordingly any fall in the Adjusted Redemption Value of the PLNs ('ARV') either on redemption or as reflected in the Company's accounts from year to year is likely to represent a taxable profit of the Company. Conversely, any increase in the ARV which is either realized on redemption (where not classified as a distribution for tax purposes) or recognised in the Company's accounts as at the end of any year is likely to result in the Company being treated for tax purposes as having made a loss equal to the amount of the increase. The board believes PIP is in a different position from Jupiter Global Green Investment Trust Plc because, over the period since PLNs were first issued by PIP, the ARV of the PLNs has not fallen significantly below the average value at which PLNs have been issued. Although the ARV of the PLNs fell by 19.2% in the year to 30 June 2002 and PLNs were redeemed in February 2002 at a redemption price lower than the ARV reflected in the Company's accounts as at the end of the immediately preceding accounting period, the tax losses brought forward from the rise in the ARV for PLNs for prior accounting periods, together with surplus expenses which PIP accumulated over these periods, should more than offset any resulting taxable profit. Since 30 June 2002, the reported ARV has risen by approximately 4.3% On the basis of the PLNs presently in issue, the value of the Company's net assets would need to fall significantly from the latest reported level before material tax liabilities are triggered. The Board continues to review the capital structure of the Company to ensure that there are continuing benefits to the Company from the use of PLNs and will report as necessary in due course. For more information: Pantheon International Participations PLC 020 7484 6200 Rhoddy Swire Pantheon Ventures 020 7484 6200 Andrew Lebus Alastair Bruce www.pipplc.com contactus@pipplc.com NOTES TO EDITORS PIP * Pantheon International Participations (`PIP') is a London quoted investment trust, managed by Pantheon Ventures Ltd., which uses an international fund-of-funds approach to private equity investment. * PIP has investments in some 300 private equity funds whose portfolios contain investments in over 3,000 companies. * The Company is the leading independent private equity fund-of-funds investor quoted on the London Stock Exchange. PIP enables individuals as well as institutions to gain access to a substantial portfolio of unquoted companies in the USA, UK, Continental Europe and Asia, within funds managed by experienced private equity managers. * Within its stated primary investment objective, the Company invests in private equity funds both by subscribing to new funds and by acquiring secondary interests. As an adjunct to this activity, the Company may occasionally acquire direct holdings in unquoted companies usually where a vendor is seeking to sell a combined portfolio of funds and direct holdings. PIP's investment policy also extends to investing directly in companies where there is a private equity manager well known to the Company investing on the same terms. Pantheon Ventures Limited * Pantheon has been active in the private equity sector since 1982. * Pantheon is the leading private equity fund-of-funds manager in Europe and currently manages over $6.9 billion. * Pantheon manages investments in 500 private equity funds in over 30 countries. * Pantheon has 65 staff, based at offices in London, San Francisco, Hong Kong and Brussels.
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