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21 May 2019


Offshore Funds Regime
All unit classes set out above meet the definition of an offshore fund as laid out in the relevant UK tax legislation. Accordingly, UK
investors should be aware of the following:
Reporting Fund Status (“RFS”)
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 July 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.