EXHIBIT 8.3 [Mourant Logo] Mourant du Feu & Jeune PO Box 87 22 Grenville Street St Helier Jersey JE4 8PX Channel Islands T +44(0)1534 609 000 F +44(0)1534 609 333 www.mourant.com Mourant du Feu & Jeune Legal Services Mourant Equity Compensation Solutions Mourant International Finance Administration Mourant Private Wealth Permanent Financing (No. 8) PLC Blackwell House Guildhall Yard London EC2V 5AE 7 June 2005 Our ref: 2016022\300706\SCOTE\MdFJ\165706\1 Dear Sirs PERMANENT MORTGAGES TRUSTEE LIMITED REGISTRATION STATEMENT ON FORM S-11 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) to be filed by the Issuer (as defined below) with the Securities and Exchange Commission under the Securities Act of 1933, as amended (the ACT), on 7 June 2005 relating to the issue by Permanent Financing (No. 8) 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 preliminary prospectus dated 25 May 2005 (the PRELIMINARY PROSPECTUS) relating to the Notes which we understand will be reproduced in the prospectus relating to the Notes and forming part of the Registration Statement (the PROSPECTUS). We confirm and adopt as our opinion the opinions set forth in the Preliminary 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 Preliminary Prospectus 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 Mourant du Feu & Jeune is a Jersey partnership Partners: A R Binnington, D J Birtwistle, E A Breen, J A J Chapman, G R P Corbin, 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, B H Lacey, W Malorey, J A Richomme, J D Rigby, B C Robins, J F Ruane, J P Speck, A J R Syvret, J C Walker, N J Weston, D R Wilson. Associates: S J V Felton, N M Hamel, M L Hamilton, D J Hopwood, G A Pollano, J H Rainer, G A Rigby, E L Scott. Consultants: K S Baker, C E Coutanche, R R Jeune C B E, P de C Mourant Jersey - Cayman - London Page 2 Permanent Financing (No. 8) PLC 7 June 2005 Our ref: 2016022\\SCOTE\MdFJ\165706\1 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 for the Notes 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" as set out in the Preliminary Prospectus and 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