<PAGE> 1
Exhibit 8.3
TAX CONSIDERATIONS UNDER THE LAWS OF SWITZERLAND
We have summarized below the principal tax consequences under the laws of
Switzerland of owning debt securities fully and unconditionally guaranteed by
UBS AG, Switzerland.
Under the scope of Swiss withholding tax legislation, debt securities issued by
an entity domiciled outside of Switzerland (issuer) are not subject to the Swiss
withholding tax of 35% on any interest payments on those securities. If the
issuer is a permanent establishment outside of Switzerland or a subsidiary, not
resident in Switzerland and vested with a guarantee by the parent company in
Switzerland, Swiss withholding tax is also not applicable if the proceeds of
such securities are not used in Switzerland. If the use of the proceeds of the
sale of debt instruments by these issuers is not in Switzerland, not only
interest payments by the issuer are free from Swiss withholding tax but also any
guarantee payment or comparable payment by Swiss parent company in connection
with such debt securities.
The guarantees relate to debt securities, which were issued by Paine Webber Inc.
before the merger with UBS Americas Inc. UBS AG and UBS Americas Inc. will make
sure that the proceeds of the former sale of these debt securities are not used
in Switzerland. Consequently, current and future interest payments on the debt
securities should not be subject to Swiss withholding tax.
Neither the present Swiss withholding tax law nor the current practice of the
Federal Tax Administration indicate that a guarantee payment related to interest
could be re-characterized as an interest payment itself, which would be subject
to withholding tax. For this reason, we believe that a possible guarantee
payment will not be subject to Swiss withholding tax, irrespective of whether it
is made for the principal, interest or other amounts payable in accordance with
the terms of the debt securities.
Zurich, December 21, 2000
Ernst & Young AG
/s/ Alfred Preisig
____________________________
Alfred Preisig
Partner tax
/s/ Urs Brugger
____________________________
Urs Brugger
Partner tax
