Medieval Attractions N.V - Page 92

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          resolved included the ownership of the intangible assets and                
          licensing structure and clarification of the process of                     
          transferring the intangible assets to the owner; the royalties              
          and management rates and contents of the supporting agreements;             
          and the method by which it was intended to repatriate the                   
          “royalty” income to the beneficial owners of intangible assets,             
          who C&L understood were largely Spanish residents.                          
               Louis deVries (deVries) was working with Medieval Times at             
          the C&L office in The Netherlands.  deVries met with Santandreu             
          and Onate on November 19 and 20, 1986.  At the meeting, they                
          discussed the “draft version of Ian Forsyth’s letter”.                      
          Santandreu and Onate had specific questions about certain items             
          in the letter.  Santandreu was of the opinion that the suggested            
          10- to 15-percent royalty rate discussed in the draft letter                
          should be calculated on gross income.                                       
               On December 9, 1986, Forsyth sent to deVries a memorandum              
          stating that C&L and Medieval Times had decided to use Manver to            
          hold the intangibles and to go ahead and try to get a tax ruling            
          for Manver from the Netherlands Antilles.  Forsyth promised                 
          deVries that he would forward a timetable of all of the actions             
          to be taken on behalf of Medieval Times in the next few days.               
               On December 11, 1986, the C&L office in the Netherlands                
          Antilles sent a letter to the Netherlands Antilles Inspector of             
          Taxes.  The letter stated that Manver was going to be receiving             
          royalties from two NV companies that were operating amusement               




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