| (i) | - | the parties who are connected persons in relation to each other may be treated as one and the same person; |
| (ii) | - | any accommodating party may be disregarded; |
| (iii) | - | the accommodating party and any other party may be treated as one and the same person; |
| (iv) | - | the arrangement may be considered or looked through by disregarding any corporate structure. |