Opinion of Linklaters , as to certain matters of U.S. taxation

EX-8.1 7 dex81.htm OPINION OF LINKLATERS , AS TO CERTAIN MATTERS OF U.S. TAXATION Opinion of Linklaters , as to certain matters of U.S. taxation

EXHIBIT 8.1

One Silk Street

London EC2Y 8HQ

Telephone (44-20) 7456 2000

Facsimile (44-20) 7456 2222

Group 4 Fax (44-20) 7374 9318

DX Box Number 10 CDE

Direct Line 020 7456 2000

Direct Fax 020 7456 2222

The Directors

InterContinental Hotels Group PLC

67 Alma Road

Windsor

Berkshire

SL4 3HD

30 October 2003

InterContinental Hotels Group PLC (the “Issuer”)

Amendment No. 1 to Registration Statement on Form F-3 in respect of up to $1,000,000,000 in aggregate principal amount of debt securities (the “Securities”) which may be guaranteed by Six Continents PLC (the “Guarantor”)

This opinion is furnished to you in connection with the Amendment No. 1 to Registration Statement on Form F-3 (the “Amended Registration Statement”) filed with the United States Securities and Exchange Commission on 30 October 2003. We have acted as United Kingdom tax advisers to the Issuer and the Guarantor in connection with the registration of the Securities under the United States Securities Act of 1933, as amended.

For the purpose of this opinion we have reviewed the Amended Registration Statement and, in our opinion, the statements under the heading “United Kingdom Taxation of Debt Securities” on pages 56 to 59 of the Amended Registration Statement are accurate and correct in all material respects, subject to the qualifications contained in those statements.

In giving this opinion, we have relied upon the truth and accuracy of the other statements made in the Amended Registration Statement.

We express no opinion as to any statements or documents other than as specified in this letter.

We hereby consent to the filing of this opinion as an exhibit to and the reference to us made under “United Kingdom Taxation of Debt Securities” in the Amended Registration Statement. In giving this consent we do not admit that we are within the category of persons whose consent is required within Section 7 of the Securities Act or the rules and regulations of the Securities and Exchange Commission thereunder.

Yours faithfully

/s/ Linklaters

Linklaters

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