Where possible the Sub-Fund will seek to invest directly rather than indirectly through a Subsidiary and/or Local Asset Owning Subsidiary. Accordingly whenever deemed necessary the Sub-Fund may create Subsidiaries. In relation to this Sub-Fund, it is not necessarily the intention that these Subsidiaries will ultimately be held by a Luxembourg Holding Company as indicated in the descriptions in the “Tax” section of the Prospectus. It is not the intention for the Sub-Fund to create a Subsidiary and/or Local Asset Owning Subsidiary for each transaction invested or jurisdiction used. The Subsidiaries and/or Local Asset Owning Subsidiary, where used, will have the following purpose:

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• As a Security Vehicle: a Subsidiary entity that will obtain the rights to the collateral being pledged to, or to be owned by, the Sub-Fund in the funding granted; or

• As a Funding Vehicle: Subsidiary entity through which the Sub-Fund indirectly provides the funding as a form of investment. This approach will be used in circumstances where it is not deemed beneficial for the Sub-Fund to contract directly with the underlying investee due to unfavourable tax and/or fiscal considerations.

 

The Subsidiary’s chosen jurisdiction of incorporation will be guided by the requirements imposed to obtain fiscal and/or legal efficiencies provided by the relevant jurisdiction pertinent to a specific investment.