EXHIBIT 8.3
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Mourant du Feu & Jeune
Permanent Financing (No. 3) plc PO Box 87
Blackwell House 22 Grenville Street
Guildhall Yard St. Helier
London EC2V 5AE Jersey JE4 8PX
Channel Islands
12 November 2003 T+44 (0)1534 609 000
F+44 (0)1534 609 333
www.mourant.com
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Dear Sirs
Mourant International
Finance Administration
PERMANENT MORTGAGES TRUSTEE LIMITED
REGISTRATION STATEMENT ON FORM S-11 Mourant Private
Wealth Management
We have acted as special Jersey tax counsel for Permanent Mortgages Trustee
Limited, a company incorporated under the laws of Jersey (the MORTGAGES
TRUSTEE), in connection with the registration statement on Form S-11 (the
REGISTRATION STATEMENT) filed by the Issuer (as defined below) with the
Securities and Exchange Commission under the Securities Act of 1933, as amended
(the ACT), on 12 November 2003 relating to the issue by Permanent Financing (No.
3) plc (the ISSUER) of certain notes (the NOTES). The Notes will be issued
pursuant to a trust deed (the TRUST DEED) between The Bank of New York (the NOTE
TRUSTEE) and the Issuer.
We have advised the Mortgages Trustee with respect to certain Jersey tax
consequences of the proposed issuance of the Notes. This advice is summarized
under the headings "SUMMARY OF PROSPECTUS - JERSEY (CHANNEL ISLANDS) TAX
STATUS" and "MATERIAL JERSEY (CHANNEL ISLANDS) TAX CONSIDERATIONS - TAX STATUS
OF THE MORTGAGES TRUSTEE AND THE MORTGAGES TRUST" in the Prospectus relating to
the Notes. We confirm and adopt as our opinion the opinions set forth in the
Prospectus under the captions "SUMMARY OF PROSPECTUS - JERSEY (CHANNEL ISLANDS)
TAX STATUS" and "MATERIAL JERSEY (CHANNEL ISLANDS) TAX CONSIDERATIONS - TAX
STATUS OF THE MORTGAGES TRUSTEE AND THE MORTGAGES TRUST". The statements
concerning Jersey tax consequences contained in the Registration Statement do
not purport to discuss all possible Jersey tax ramifications of the proposed
issuance of the Notes and are limited to the matters expressly referred to in
those statements.
We hereby consent to the filing of this letter as an exhibit to the Registration
Statement and to a reference to this firm (as counsel to the Mortgages Trustee)
under the headings "SUMMARY OF PROSPECTUS - JERSEY (CHANNEL ISLANDS) TAX STATUS"
and "MATERIAL JERSEY (CHANNEL ISLANDS) TAX CONSIDERATIONS - TAX STATUS OF THE
MORTGAGES TRUSTEE AND THE MORTGAGES TRUST" in the Prospectus forming a part of
the Registration Statement and on the inside back cover of the Prospectus,
without implying or admitting that we are "experts" within the meaning of the
Act or the rules and regulations of the Securities and Exchange Commission
issued thereunder, with respect to any part of the Registration Statement,
including this exhibit.
We consent to the inclusion in the listing particulars of our name and the
reference to our advice to the Mortgages Trustee under the headings "SUMMARY OF
PROSPECTUS - JERSEY (CHANNEL ISLANDS) TAX STATUS" and "MATERIAL JERSEY (CHANNEL
ISLANDS) TAX CONSIDERATIONS - TAX STATUS OF THE MORTGAGES TRUSTEE AND THE
MORTGAGES TRUST" and
Mourant du Feu & Jeune is a Jersey partnership
Partners: A R Binnington, E A Breen, J A J Chapman, J D P Crill, C L I Davies,
N C Davies, E C Devenport, S M Gould, T J Herbert, R A Hickling, I C James,
R F V Jeune, B H Lacey, W Malorey, J A Richomme, J D Rigby, B C Robins,
J P Speck, A J R Syvret, J C Walker, N J Weston, D R Wilson. Associates:
D J Birtwistle, C R Davies, M I Guillaume, N M Hamel, M L Hamilton, G A Pollano,
J F Ruane, E L Scott. Consultants: K S Baker, C E Coutanche, R R Jeune C B E,
P de C Mourant Mourant du Feu & Jeune London: 4 Royal Mint Court, London,
EC3N 4HJ
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12 November 2003
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authorise the contents of such advice for the purposes of
Article 6(1)(e) of the Financial Services and Markets Act 2000 (Official
Listing of Securities) Regulations 2001.
We do not express any opinion as to any laws of any jurisdiction other than the
laws of Jersey (Channel Islands) as such laws are applied by the courts of
Jersey as at the date of this letter.
Yours faithfully
/s/ Mourant du Feu & Jeune
MOURANT DU FEU & JEUNE