Attached files
file | filename |
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8-K - FORM 8-K - Avago Technologies LTD | f57548e8vk.htm |
EX-1.1 - EX-1.1 - Avago Technologies LTD | f57548exv1w1.htm |
EX-5.1 - EX-5.1 - Avago Technologies LTD | f57548exv5w1.htm |
EX-8.2 - EX-8.2 - Avago Technologies LTD | f57548exv8w2.htm |
Exhibit 8.1
6 December 2010
Avago Technologies Limited
1 Yishun Avenue 7
Singapore 768923
1 Yishun Avenue 7
Singapore 768923
Dear Sirs
AVAGO TECHNOLOGIES LIMITED (THE COMPANY) PROSPECTUS SUPPLEMENT FILED PURSUANT TO RULE
424(b) PROMULGATED UNDER THE SECURITIES ACT (AS DEFINED HEREIN) IN RESPECT OF THE VENDOR SHARES (AS
DEFINED HEREIN)
We have acted as Singapore legal advisers to Avago Technologies Limited (the Company), a
company incorporated under the laws of Singapore, in connection with the filing by the Company with
the United States Securities and Exchange Commission of a prospectus supplement (the
Prospectus Supplement) filed pursuant to Rule 424(b) promulgated under the Securities Act
of 1933, as amended (the Securities Act), in respect of (a) 25,000,000 ordinary shares
(the Vendor Shares) offered by certain selling shareholders of the Company (the
Vendors), and (b) up to 3,750,000 ordinary shares which may be purchased by the
underwriters pursuant to an option to purchase additional ordinary shares granted by the Vendors.
You have requested our opinion concerning the statements in the Prospectus Supplement under the
section Tax ConsiderationsSingapore Tax Considerations, comprising the subsections Income
Taxation under Singapore Law, Stamp Duty, Estate Duty and Tax Treaties Regarding Withholding
Taxes.
The facts, as we understand them, and upon which with your permission we rely in rendering the
opinion herein, are set forth in the Prospectus Supplement.
We are opining herein as to the effect on the subject transaction only of the tax laws of Singapore
as at the date of this opinion and as such laws have, to date, been interpreted in published
decisions of the courts of the Republic of Singapore. We express no opinion with respect to the
applicability thereto, or the effect thereon, of the laws of any other jurisdiction.
Based on such facts and subject to the limitations set forth in the Prospectus Supplement, the
statements of law and legal conclusions in the Prospectus Supplement under the section Tax
ConsiderationsSingapore Tax Considerations, comprising the subsections Income Taxation under
Singapore Law, Stamp Duty, Estate Duty and Tax Treaties Regarding Withholding Taxes,
constitute the opinion of WongPartnership LLP as to the material Singapore tax consequences of an
investment in the ordinary shares.
No opinion is expressed as to any matter not discussed herein.
We will not be responsible to carry out any review or to update the opinion for any subsequent
changes or modifications to the law and regulations, or to the administrative interpretations
thereof.
We hereby consent to the filing of this opinion as an exhibit to the Companys Current Report on
Form 8-K dated the date hereof filed by the Company and to the use of our name under the section
Tax Considerations Singapore Tax Considerations in the Prospectus Supplement. In giving such
consent, we do not hereby admit that we are within the category of persons whose consent is
required under Section 7 of the Securities Act or the rules or regulations of the SEC promulgated
thereunder.
This opinion given herein is strictly limited to the matters stated herein and is not to be read as
extending by implication to any other matter in connection with the offering (as described in (a)
and (b)), or otherwise including, but without limitation, any other document signed in connection
with the offering (as described in (a) and (b)). Further, save for the filing of this opinion with
the SEC as an exhibit to the Prospectus Supplement, this opinion is not to be circulated to, or
relied upon by, any other person (other than persons entitled to rely on it pursuant to applicable
federal securities laws in the United States, if applicable) or quoted or referred to in any public
document or filed with any governmental body or agency without our prior written consent.
Yours faithfully WONGPARTNERSHIP LLP |
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/s/ WongPartnership LLP | ||||
TAN KAY KHENG/ TAN SHAO TONG | ||||