Rabobank Nederland & Rabo Capital Securities Limited

This product ruling applies to the 2009 capital raising by the applicants, through Rabo Capital offering to the public, NZ dollar denominated, perpetual, non-cumulative, non-voting preference shares ("PIE Capital Securities"). The ruling sets out the income tax treatment of distributions or dividends paid to the holders of those PIE Capital Securities and renews an earlier ruling (BR Prd 10/01) that expired on 30 June 2014.