For the time being, the Sub-Fund will seek to invest directly rather than indirectly through a subsidiary and/or local asset owning subsidiary. However, when deemed necessary by the Board of the Company, 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 main 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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a) 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

b) As an Investment Vehicle: subsidiary entity through which the Sub-Fund indirectly provides short-term structured capital 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.