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10 May 2019


The Taxation (International and Other Provisions) Act 2010 and the Offshore Funds (Tax) Regulations (SI 2009/3001) (the “new
regime”) provide that, unless a fund is approved by HMRC as a “reporting fund”, any gains arising to unit holders resident or
ordinarily resident in the UK on sale, redemption or other disposal of units (including deemed disposal on death) will be taxed as
offshore income rather than capital gains.
The unit class set out above has been accepted as a reporting fund with effect from 1 June 2011. It is our intention that this unit
class will maintain its qualification as a reporting fund in order for UK investors to enjoy the typically more advantageous tax
treatment of capital gains.
The below statements on taxation are intended to be a general summary of the UK tax treatment that may be applicable to UK
investors in the following unit classes within Lyxor ETF funds:
Fund Unit Class ISIN Reference
Lyxor FTSE EPRA Nareit Developed Europe UCITS ETF D-EUR FR0010833558
Transparent Fund Regime
The above listed funds are French Fonds Commun de Placement (‘FCP’) managed by Lyxor International Asset Management. An
FCP is treated as transparent for income tax purposes and opaque for capital gains tax purposes on UK investors. Specifically, the
income returns of the funds are taxed directly on the investors as the income arises to the FCP as the investors are deemed to hold
the underlying investments directly by themselves, whereas capital returns are deferred until the fund units are disposed of by the