HEG : ANNEXURE-8

[To be provided on Shareholder's Letter head]

Annexure 8

DECLARATION FOR NON‐RESIDENT SHAREHOLDERS

(To be declared by non‐resident shareholder for availing the benefits of lower tax deduction under Section 90 of the Indian Income Tax Act, 1961 ('Act') read with the provisions of the Tax Treaty with India and the Multilateral Instrument)

Date: ___/____/2021

To

HEG Limited,

Subject: Declaration regarding applicability of tax treaty and beneficial ownership

I / We, [____________________________] do hereby solemnly declare as follows:

1. I / We, am / are a resident of ________________[name of country of which shareholder is tax resident] during the year 2021‐22. I / We am / are eligible to be governed by the provisions of the tax treaty between India and _____________[name of country of which the shareholder is tax resident] and meet all the necessary conditions to avail the benefits under the said tax treaty.
2. I / We do not have a Permanent Establishment (PE) / Fixed base / Place of Effective Management in India; or dividend income receivable by me / us from investment in the shares of HEG Limited is not attributable / effectively connected to any PE / fixed base in India.
3. Further, I/We do not have a Business Connection in India according to the provision of section 9(1)(i) of the Act and the amounts paid/payable to us, in any case, are not attributable to business operations, if any, carried out in India.
4. That the investments made by me / us in the shares of HEG Limited are not arranged in a manner which results in obtaining a tax benefit, whether directly or indirectly, as one of its principal purposes. The tax benefit, if any, derived from such investments would be in accordance with the object and purpose of the relevant provisions of the tax treaty between India and ________________[name of country of which the shareholder is tax resident]
5. *I am / We are the beneficial owner of the investments made by me/us in the shares of HEG Limited

and also any income receivable from such investments, for a period of less than 365 days.

OR

*I am / We are the beneficial owner of the investments made by me/us in the shares of HEG Limited and also any income receivable from such investments, for an uninterrupted period of 365 days or more including the date of payment of the dividends.

OR

*I am / We are the beneficial owner of the investments made by me/us in the shares of HEG Limited and also any income receivable from such investments, for a period of more than '____' days[required

period of days under the relevant Double Taxation Avoidance Agreement].

1. I / We further declare that I / we have the right to use and enjoy the dividend received / receivable from the above shares and such right is not constrained by any contractual and / or legal obligation to pass on such dividend to another person.
2. I / We further declare that I / We are eligible to claim benefit of the tax treaty between India and
   ______________________[Name of the Country of residence of shareholder] including satisfaction of the Limitation of Benefits clause (wherever applicable).
3. I / We undertake to intimate HEG Limited immediately in case of any alteration in the aforesaid declaration.
4. I, [____________________________], hereby declare that the contents above are correct, complete and truly stated.

(Name, designation & signature of Non‐resident Shareholder)

Company Seal (if applicable)

Date: _________

Place: _________

Address: ________________

Email and Telephone:__________________________

Tax identification number (country of residence):_________________

Notes:

1. *Delete whichever is not applicable.