Paragraph 14 of the Information Memorandum briefly summarises some important tax principles for Luxembourg that may be or become relevant in relation to the Fund. This summary is based on the laws, regulations and practices in force and applied in Luxembourg as at the date of the Information Memorandum. The statements are subject to possible changes in the laws or their interpretation that become effective after this date (possibly with retroactive effect).
Although this summary is based on the laws currently in force in Luxembourg, it does not constitute legal or tax advice and should not be construed as such. It is provided for information only. Prospective Investors are advised to consult their own tax advisers regarding the tax consequences of an investment in the Fund. This includes, but is not limited to, the effect of state or local taxes or church taxes under Luxembourg law and, in the case of Investors not resident in Luxembourg, the tax consequences in the respective countries of residence. This also applies to cases where there are doubts about the tax position of certain aspects or transactions associated with an investment in the Fund. This summary is a brief outline of the Fund’s view on the tax implications of an investment in the Fund. However, it does not constitute a guarantee that these tax and legal consequences will also occur.
The summary may not form the sole basis for assessing the tax impact of an investment in the Fund, in particular because the tax impact will depend on the specific situation of each Investor. The brief outline is therefore limited to a summary of possible tax effects. We do not claim that this paragraph fully summarises the tax rules and practice currently in force in Luxembourg, nor that it contains any explanations of the tax treatment of an investment in the Funds in jurisdictions other than Luxembourg. In addition, this section does not address how the taxation of the fund is structured in other jurisdictions or how the taxation of subsidiaries, partnerships and intermediary companies of the fund or investment structures in which the fund has a holding in a specific jurisdiction is structured.
Prospective investors are advised to consult their own professional tax advisers with respect to the potential tax consequences of buying, holding, redeeming, converting or selling shares in the fund under the laws of their country of citizenship, residence, domicile and incorporation. Investors are fully responsible for the fulfilment of their obligations under the respective national tax law.