Luxembourg Investment Vehicles

Taxation UCITS ("Part I Fund") Income tax Regulated Investment Vehicles Part II Fund with authorised AIFM SIF with authorised AIFM SICAR with authorised AIFM Tax exempt. Tax exempt. Tax exempt. Tax exemption for income and capital gain derived from transferable securities connected with investments in risk bearing capital. Tax exemption for one year for income on cash held for the purpose of a future investment. The remaining income is subject to the ordinary income tax of 24.94 % (Municipal Business Tax + Corporate Income Tax - Luxembourg city 2019). Withholding tax on dividends and capital gains Not subject to withholding tax. Subscription tax • 0.05% of NAV, except: 0.01% of NAV for money market funds, cash funds or share-classes of UCIS reserved to one or more institutional investors. Exemption for special institutional money market funds, pension funds, exchange traded funds, microfinance funds and funds investing in other funds already subject to the subscription tax. Not subject to withholding tax. 0.05% of NAV, except: 0.01% of NAV for money market funds, cash funds or share-classes of UCIS reserved to one or more institutional investors. • Exemption for special institutional money market funds, pension funds, exchange traded funds, microfinance funds and funds investing in other funds already subject to the subscription tax. Not subject to withholding tax. 0.01% of NAV annually. • Tax exemption possible for certain money market, microfinance funds and pension funds or SIFs investing in other funds already subject to subscription tax. Not subject to withholding tax. No subscription tax. Net wealth tax Tax exempt. Capital duty No proportional capital duty. Value Added tax (VAT) VAT exemption on management services. Tax exempt. No proportional capital duty. VAT exemption on management services. 36 KPMG Luxembourg Investment Vehicles Tax exempt. No proportional capital duty. Only subject to minimum net wealth tax. No proportional capital duty. VAT exemption on management services. VAT exemption on management services.

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