Exhibit 8.3
| | | Allen & Overy LLP
1221 Avenue of the Americas
New York NY 10020 USA |
AEGON N.V.
AEGONplein 50
P.O. Box 202
2501 CE The Hague
The Netherlands | |
Tel +1 212 610 6300
Fax +1 212 610 6399
www.allenovery.com |
June 28, 2006 |
|
42338-00443 NY:1275026.2 |
Ladies and Gentlemen:
We have acted as US tax counsel to AEGON N.V. (theIssuer), in connection with the preparation of the Prospectus Supplement dated June 21, 2006 filed with the Securities and Exchange Commission (theCommission) pursuant to Rule 424 under the Securities Act of 1933, as amended (theSecurities Act), on June 22, 2006 (theProspectus Supplement) of which the Prospectus dated May 20, 2005 (theProspectus) forms a part. The Prospectus Supplements and Prospectus have been filed with the Commission as part of the Issuer's registration statement on Form F-3, as amended (file no. 333-71438), declared effective on October 22, 2001 (theRegistration Statement). The Registration Statement, Prospectus and Prospectus Supplement relate to the registration under the Securities Act of an aggregate face amount of $500,000,000 6.875% perpetual capital securities (theSecurities).
As US tax counsel, we have advised the Issuer with respect to certain general US federal income tax consequences of the proposed issuance of the Securities. This advice is summarized under the heading "Taxation in the United States" in the Prospectus Supplement (theDiscussion) which is part of the Registration Statement. We hereby confirm that the statements set forth in the Discussion represent our opinions as to the matters of law covered by them, subject to the qualifications stated therein.
We are aware that we are referred to in the Discussion and under the heading "Legal Matters" in the Prospectus Supplement. We hereby consent to the references to us in those sections and the filing of this letter as an exhibit to the Registration Statement without thereby implying or admitting that we are "experts" within the meaning of the Securities Act or the rules and regulations of the Commission issued thereunder, with respect to any part of the Registration Statement, including this exhibit.
Very truly yours,
Allen & Overy LLP
