Pursuant to Section 140 (1) Austrian Investment Fund Act 2011 (“InvFG 2011”), the Austrian Financial Market Authority (“Finanzmarktaufsicht”) has been notified of the intention to publicly distribute share/unit classes of the fund in Austria and is authorised to do so from the end of the notification procedure.

Paying agent

UniCredit Bank Austria AG, Schottengasse 6-8, A-1010 Vienna (the "Austrian Paying Agent"), has been appointed as paying agent in Austria according to § 41 Abs 1 iVm § 141 Abs 1 InvFG 2011 (see also 92 RL (EU) 2019/1160). In addition to the normal redemption and switching procedures investors resident in Austria may - following the pre-conditions set out above) - alternatively redeem or switch their shares/units through the Austrian Paying Agent. Any payments to investors may also be effected through the Austrian Paying Agent.

Information agent

The sales prospectus, the PRIIPs KIDs, the most recent annual and half-yearly report, as well as the offer and redemption price may also be obtained free of charge from UniCredit Bank Austria AG at the stated address.

Tax representative

The fund has appointed KPMG Alpen-Treuhand Wirtschaftsprüfungs- und Steuerberatungsgesellschaft, Porzellangasse 51, 1090 Wien as tax representative according to § 186 par. 2 no. 2 in connection with § 188 Investment Fund Act 2011.

Publication of prices

The calculated values of a fund can be obtained from the paying agent UniCredit Bank Austria AG, Schottengasse 6-8, A-1010 Wien. The calculated values of the fund or sub-funds can be seen on the fund’s homepage. www.structuredinvest.lu

Taxation in Austria

The following information is supposed to give a general overview of the principles of Austrian taxation on income derived from investment funds for investors subject to unlimited tax liability in Austria based on the legal status applicable since 1 April 2012. Particularities of individual cases are not considered. As no concrete advice on the taxation of individual investors is hereby given, it is recommended that investors seek advice from a tax advisor regarding the taxation of their respective holdings.

1. General information

Investment funds are transparent according to Austrian tax law. This means that income from a fund is not taxed at fund level but at investor level (tax transparency).

The fund’s income is generally taxable, when it is distributed to the investors. Income, which is not distributed, is taxable as deemed distributed income (“DDI”) once a year.

The Investment Fund Act 2011 generally provides for two tax categories for foreign investment funds:

• Investment funds, which have a tax representative, who calculates the 25% withholding tax on distributions and DDI and reports the tax figures to the OeKB (reporting funds) and
• Investment funds, which do not have a tax representative and which are therefore subject to the lump-sum taxation (black funds). The lump-sum taxation is based on the higher of the following two amounts: 90% of the difference between the first and the last redemption price of the calendar year or 10% of the last redemption price of the calendar year

2. Private investors

2.1. Taxation of the fund’s income

The taxable fund’s income consists of the net investment income (i.e. interest income, dividend income, other ordinary income minus the fund’s expenses) and 60% or 100% of the realised capital gains from the sale of securities and of the income from derivative instruments.

Realised capital losses (after netting with realised capital gains) can be credited against the ordinary income (dividends, interest and other income minus expenses). If capital losses exceed the net investment income, the exceeding amount can be carried forward at share/unit class level. Also, a negative net investment income can be offset against realised capital gains and carried forward if the negative net investment income exceeds the realised capital gains. In the following financial years, these carry forwards have to be offset in a first step against realised capital gains and in a second step against the net investment income.

2.2. Taxation of the DDI

In case of foreign investment funds, the annual Austrian DDI figures have to be reported within seven months after the fund’s financial year end by the Austrian tax representative. The applicable tax rate for private investors on the fund’s income is generally 25% KESt. In case the fund shares/units are held on Austrian deposit, the 27.5% KESt on the DDI is withheld by the Austrian depository bank when the tax figures are reported to OeKB. In case the fund shares/units are held on foreign deposit the DDI (which is deemed to be distributed four months after the fund’s financial year-end in this case) has to be included in the private investor’s personal income tax return and is subject to special 27.5% tax rate.

2.3. Taxation of distributions

Distributed income is subject to 25% tax. In case the fund shares/units are held on Austrian deposit, the 25% tax on the distribution (KESt) is withheld by the Austrian depository bank. In case the fund shares/units are held on foreign deposit the distributed income has to be included in the private investor’s personal income tax return and is subject to special 27.5% tax rate.

2.4. Sale of fund shares/units

In case private investors sell their fund shares/units, the difference between the sales price and the purchase price is subject to 27.5% KESt irrespective of the holding period. In order to avoid a double taxation of the DDI (i.e. annual taxation and taxation as part of the gain derived from the sale of the fund shares/units) the fund share’s/unit's purchase price is increased annually by the taxed DDI. It has to be considered that the sales (preliminary) charge must generally not be considered as incidental acquisition cost. If the fund shares/units are held on Austrian deposit, the 27.5% tax on the capital gain shall be withheld by the Austrian depositary bank. In case the fund shares/units are held on foreign deposit, the capital gain has to be included in the private investor’s personal income tax return.

3. Individuals holding the fund shares/units as business property

If fund shares/units are held by individuals as business property (sole proprietors or partnerships), the tax rules as described above for private investors are generally applicable with the following exemptions:

• Individuals holding the fund shares/units as business property have to include the realised capital gains into the income tax return. The capital gains are subject to 27.5% tax. Any tax withheld on capital gains by the Austrian depositary bank will be credited on the individual’s income tax.
• 100% of the accumulated realised capital gains are taxable.
• The sales (preliminary) charge can be considered as incidental acquisition cost and have to be included in the individual’s income tax.

4. Corporate Investors

The net investment income as well as all realised capital gains are subject to 25% Corporate Income Tax and must be included in the corporate income tax return of the corporation. If the corporate investor sells fund shares/units, the difference between the purchase price and the sales price less already taxed DDI is subject to 25% Corporate Income Tax (irrespective of the holding period) and must be included in the corporate income tax return. The DDI is deemed to be received by corporate investors at the financial year-end of the fund.

Corporate investors can avoid the withholding tax deduction by way of providing the Austrian bank with a certificate of exemption. If no certificate of exemption is provided, the deducted withholding tax can be credited against the Corporate Income Tax.

5. Disclaimer

Please note that the information on the tax consequences according to the above is based on the current tax rules. The correctness of this tax information can be affected by subsequent changes in the law or changes in the application of the law.

In accordance with the Bulgarian Collective Investment Schemes and Other Undertakings for Collective Investment Act as further amended ("CISOUCIA"), the Bulgarian Financial Supervision Commission ("FSC") has been notified of the intention to publicly distribute share/unit classes of investment funds in Bulgaria.

UniCredit Bulbank AD having its registered office at Sofia, Sveta Nedelya square 7, Bulgaria, acts as the Sub-Distributor for Bulgarian investors, and is authorised to receive subscription, redemption orders. Redemption proceeds, any distributions and payments to Bulgarian investors are made through UniCredit Bulbank AD. Pursuant to article 128 and the following from Bulgarian Law on collective investment schemes and other undertakings for collective investments a collective investment scheme established in another Member State may propose its shares/units in Bulgaria after the competent authority of such Member State notifies Bulgarian Financial supervision commission.

The notification shall be made by forwarding of the notification letter prepared by the collective investment scheme, accompanied by an attestation issued by the competent authority of the collective investment scheme's home Member State, certifying compliance of the scheme with the requirements set out in Directive 2009/65/EC.

The notification letter shall contain information about the measures taken for marketing of the shares/units of the collective investment scheme on the territory of the Republic of Bulgaria, the measures for marketing the respective classes of shares/units and also information that the shares/units will be marketed by the scheme's management company, enclosing the following thereto:

1. the constituent instruments of the collective investment scheme, the prospectus, the last annual and half-yearly reports in Bulgarian or English;

2. the document with the PRIIPS KID in Bulgarian.

The notification letter shall contain the address, as well as the other information necessary for the issuance of an invoice or for the communication of the applicable Commission’s fees for supervision, as well as information about the about measures. The notification letter and the attestation shall be submitted in English.

A collective investment scheme established in another Member State shall provide to investors in the Republic of Bulgaria access to all the information and documents available to the investors in its home Member State. The document with the PRIIPS KID shall be provided to the investors in the Republic of Bulgaria in Bulgarian and any other information may be provided at the choice of the collective investment scheme in Bulgarian or in English. The translation of the document with the PRIIPS KID and of any other information shall reflect accurately and completely the content of the original. The requirements for provision of information and documents shall also apply to any subsequent change and update.

The issue and redemption prices are available at www.structuredinvest.lu and can be obtained free of charge from the UniCredit Bulbank AD.

The following documents are available at UniCredit Bulbank AD free of charge or can be downloaded from www.structuredinvest.lu:

• Prospectus
• PRIIPS KID
• The Articles of Incorporation
• The current annual report and, if published, the current semi-annual report
• all the documents listed in the fund’s prospectus

Taxation in Bulgaria

The below overview is based on the Bulgarian tax legislation as of the date of the prospectus and may be subject to changes in case of amendments to the Bulgarian tax law. The following information is a general overview of the principles of the taxation on income form investment funds according to the Bulgarian tax law and it does not represent a tax advice to investors.

The below overview is based on the Bulgarian Personal Income Tax Act (PITA) and the Bulgarian Corporate Income Tax Act (CITA).

I. General overview

Capital gains tax standard rate in Bulgaria is 10%. However, exempted from taxation is the trading:

• in shares/units of collective investment schemes and national investment funds concluded on a regulated market according to Art. 152, para. 1 and 2 of the Bulgarian Financial Instruments Markets Act;
• in shares/units and rights that can be exercised to participate in capital increases concluded on a regulated market;
• in government securities concluded on a regulated market according to Art. 152, para. 1 and 2 of the Bulgarian Financial Instruments Markets Act;
• executed under the terms and according to the procedures for repurchase or redemption by collective investment schemes and national investment funds, which have been admitted to trading on a regulated market in Bulgaria or in another European Union (EU) / European Economic Area (EEA) country;
• executed under the terms and in accordance with the procedures for tender offers as outlined in the Public Offering of Securities Act or similar provisions in other EU/EEA countries.

II. Bulgarian Tax Residents

1.    Private Individual Investors

Bulgarian tax residents are taxed on capital gains and investment income realised from all sources during their period of residence. Capital gains are taxed on an annual basis with a 10% flat tax rate through the submission of the personal annual tax return. The taxable income shall be equal to the aggregate of the profit realized during the respective calendar year under each specific transaction decreased by the amount of the losses realized during the year under each specific transaction. This means that each transaction shall be listed separately on the tax return. The taxable income is the positive difference between the sale price and the purchase price and is taxed with 10% tax rate. The above mentioned exemptions in respect of capital gains are applicable and should be taken into consideration.

Individuals are required to report and tax their foreign dividend/interest income on an annual basis through the submission of the annual tax return. The dividend income is taxed with 5% tax rate and interests with 10%. Taxable persons are entitled to a tax credit in case a tax has already been paid abroad. However, the tax credit shall be limited to the amount of the Bulgarian tax on these incomes.

2.    Corporate Investors

The realised capital gains by legal entities are included in their corporate income and are taxed at the full corporate income tax rate of 10%. Similar to individuals, the exemptions above apply, i.e. capital gains from trade in listed securities (shares/units of collective investment funds and others) on regulated markets in the EU/EEA are not subject to taxation.

Dividend income deriving from local or EU/EEA based companies are tax exempt. Non-exempt dividends are taxed as part of overall taxable profits. 

Interest income is included in the financial results of the legal entities and is subject to 10% corporate income tax.

III. Non-Bulgarian Tax Residents

1.    Private Individual Investors

Foreign tax residents are taxed only on the capital gains and investment income derived from sources in Bulgaria. Hence, the foreign capital gains (as well as the foreign dividend income and interests derived from the collective investment units) of non-Bulgarian tax residents are not subject to taxation in Bulgaria with respect to the discussed in the prospectus collective investment shares/units as far as the latter are from source outside Bulgaria.

2.    Corporate Investors

Legal entities which are non-Bulgarian tax residents are not subject to tax in Bulgaria with respect to any income resulting from the acquisition, holding, redemption or sale of the collective investment shares/units (incl. any dividend and interest income) provided that they do not have a permanent establishment in Bulgaria to which a transaction with the collective investment units can be related.

IV. Impact of a Double Tax Treaty between Bulgaria and the Jurisdiction of the Fund

Where applicable, the provisions of the respective double tax treaty in force between Bulgaria and the jurisdiction of the fund should be taken into consideration with respect to the taxation of the capital gains realised from the disposal of the collective investment shares/units. Such provisions may decrease the amount of the tax due or lead to tax exemption in Bulgaria or the respective other country.

V. Withholding tax

As far as the issuer of the collective investment units (the fund) is a non-Bulgarian tax resident, the possession and/or the transactions with/redemption of the collective investment shares/units shall not be subject to withholding tax in Bulgaria according to the Bulgarian tax legislation.

Capital gains from transactions with financial assets admitted to trading on a regulated market and to public offer in Bulgaria, in another EU member state or state of the EEA are also exempt from withholding tax at the source.

Only investments in a foreign standard fund that has duly notified public marketing to the Czech National Bank pursuant to Article 93 of the UCITS Directive and also has ensured the fulfilment of the certain tasks pursuant to Section 306 of Act No 240/2013 Coll. on management companies and investment funds (the "AMCIF") can be marketed publicly in the Czech Republic.

The performance of tasks under Section 306 of the AMCIF are as follows and those tasks can be arranged electronically or in another manner enabling remote access:

• the performance of instructions concerning the issuing, subscription and purchasing of securities or registered securities issued by the fund in the Czech Republic and the performance of the related payments, in accordance with the conditions contained in documents pursuant to Section 307 of the AMCIF;
• the provision of information to investors about how the instructions pursuant to the previous paragraph can be performed and on the division and payment of shares/units in the profit and other yields from the assets of the fund in the Czech Republic;
• the establishment of suitable procedures and measures to ensure the proper discussion of investor complaints and the removal of all restrictions for investors when claiming their rights;
• making information and documents available to investors for inspection and obtaining copies under similar conditions to those in Section 307 of the ACMIF;
• the provision of information to investors concerning the tasks that people perform, on a permanent data carrier; and
• ·the operation of the contact point for communication with the relevant bodies.

The public marketing of investments in a foreign standard fund in the Czech Republic is governed by Sections 305 to 307 of the AMCIF.

In case of publicly marketed investments to a foreign standard fund, the following up-to-date documents (as well as amendments thereof) in relation to the foreign standard fund must be made available to investors at their registered office or residence in the Czech Republic and be published on the internet pages of the foreign standard fund:

• a PRIIPS KID;
• a statute of the foreign standard fund;
• an annual report of the foreign standard fund;
• a semi-annual report of the foreign standard fund; and
• information on the amounts at which securities issued by the foreign standard fund are issued and redeemed.

All marketing communications and promotional materials must be clearly identifiable as such. They shall be fair, clear, not misleading and comply with the requirements of Sections 243 and 244 of the AMCIF. Where the net asset value of securities or registered securities issued by a foreign standard fund is likely to have a high volatility, marketing communications shall include a prominent statement drawing attention to that characteristic. Where a foreign standard fund does invest principally in transferable securities or Money Market Instruments, or where a foreign standard fund replicates an equity or debt securities index and observe other benchmark, its prospectus and, where necessary, marketing communications shall include a prominent statement drawing attention to the investment policy.

Marketing materials do not need to be sent to the Czech National Bank in advance. The Czech National Bank does not check, approve or give consent to their use before the start of marketing of a foreign standard fund in the Czech Republic. 

Distributor in Hungary

In accordance with Section 119 (3) of Act XVI of 2014 on Collective Investment Funds and Their Managers and on the Amendment of Financial Regulations (“Investment Fund Act”) the Hungarian National Bank (“HNB”), acting as the financial supervisory authority in Hungary was duly notified of the intention to publicly distribute share/unit classes of the investment fund in Hungary. Pursuant to Section 119 (3) of the Investment Fund Act, the distribution agreement concluded with the Distributor was submitted to the HNB.

UniCredit Bank Hungary Zrt., having its registered office at 1054 Budapest, Szabadság tér 5-6, Hungary, acts as the Distributor for Hungarian investors, and is authorised to receive subscription, redemption, and conversion orders. Redemption proceeds, any distributions and payments to Hungarian investors are made through UniCredit Bank Hungary Zrt.

The following documents are available at UniCredit Bank Hungary Zrt. free of charge or can be downloaded from www.structuredinvest.lu:

• Prospectus
• PRIIPS KID – available in Hungarian as well
• Annual and semi-annual report
• All the documents listed in the fund’s prospectus

As prescribed by Section 119 (1) of the Investment Fund Act, the PRIIPS KID is provided to the Hungarian investor upon such request free of charge and in a written form by UniCredit Bank Hungary Zrt. at the time of the conclusion of the contract.

The issue and redemption prices are available at www.structuredinvest.lu and can be obtained free of charge from the UniCredit Bank Hungary Zrt.

Taxation in Hungary

I. General overview

The following is an overview of the potentially applicable Hungarian tax liabilities with regard to the investment in the shares/units which qualify as collective investment units. The overview does not address tax considerations applicable to investors of shares/units that may be subject to special tax rules, including, among others, controlled foreign companies (“CFCs”), non-business carrying entities, income tax-exempt entities or companies, enterprises subject to special, elected or obligatory tax regimes. The overview does not cover situations where (i) individuals hold the shares/units in the context of business activities, (ii) the shares/units are held as current assets (i.e. allocable to the inventory or otherwise held for trading purposes) or (iii) the shares/units are received and handled by the private individual or corporate investor due to or under a special arrangement or relationship between the private individual or corporate investor and a fund or a third party.

This overview is based on the tax laws of Hungary as in effect and applied on the date of this document, and is subject to changes in Hungarian law, including changes that could have a retroactive effect. The following overview is not exhaustive and does not take into account or discuss the tax laws of any country other than Hungary.

Note that the tax treatment of certain categories of shares/units is not in all respects established and is, therefore, uncertain to some extent. In particular, there are no specific tax laws addressing the tax treatment of certificates in Hungary, nor is there any court practice specifically available in respect of certificates.

This overview is based on the Hungarian Personal Income Tax Act (Act CVXII of 1995, as amended) (“PIT Act”) and the Hungarian Corporate Income Tax Act (Act LXXXI of 1996, as amended, as amended) (“CIT Act”).

This overview addresses neither Hungarian inheritance nor gift tax consequences.

II. Non-Hungarian Tax Residents

1. Private Individual Investors

Private individual investors, who are not tax resident in Hungary, shall not be liable to tax on their income from the shares/units provided that the fund is not Hungarian tax resident or it is not obliged to pay the interest, qualifying as such under the PIT Act, through its Hungarian permanent establishment, branch office or commercial representative office.

2. Corporate Investors

A non-Hungarian tax resident corporate investor shall not be subject to tax in Hungary with respect to any income resulting from the acquisition, holding, redemption or sale of shares/units, provided that it does not have a permanent establishment in Hungary to which such transaction with the shares/units can be related.

III. Hungarian Tax Residents

1. Private Individual Investors

The income of a Hungarian tax resident private individual investor, arising from the acquisition, holding, or redemption of shares/units which qualify as collective investment units and publicly offered and traded is subject to PIT in Hungary as interest income at the rate of 15 per cent. Income from the sale of such shares/units at arm's length price on a controlled market of any member state of the EEA or OECD or on the stock exchange under Act CXX of 2001 on the Capital Market is subject to PIT in Hungary as income from controlled capital market transactions at the rate of 15 per cent. The profit and loss of controlled capital market transactions during the tax year can be totalled and the PIT assessed accordingly. Losses of previous two tax years can be used to offset the taxable profit of the tax year, subject to certain conditions.

2. Tax allowance and exemption

Favourable tax treatment could be applied on income from long-term investments in Hungary under Section 67/B of the PIT Act. The tax allowance and tax exemption could be applied on the income under a long-term investment contract (in Hungarian, "tartós befektetési számla") ("LTIC") concluded between the private individual and an investment service provider or a credit institution. The LTIC itself is a separate agreement where the parties agree to observe the taxation rules laid down in the PIT Act in order the private individual to be eligible for the below tax allowance or exemption.

In accordance with the rules of the LTIC, the private individual shall conclude an LTIC with an investment service provider or a credit institution and place funds (at least HUF 25,000) on the LTIC account. The calendar year of opening the LTIC account is regarded as the collection year and funds can only be placed until the 31st of December of such year. The placed funds can be used, in the collection year and the subsequent years, in general, to invest in debt securities and controlled capital market transactions.

The withdrawal of funds, including the yield from the investments, from the LTIC account after the end of the third year following the collection year shall be subject to 10% PIT. The withdrawal of funds, including the yield from the investment, from the LTIC account after the end of the fifth year following the collection year shall be exempt from PIT.

An agreement concluded with a foreign investment service provider/credit institution could also be regarded as an LTIC if (i) it is in compliance with the PIT Act, (ii) the parties apply the respective rules of the PIT Act on their rights and obligation and (iii) the private individual undertakes to (a) tie-up at least cash amounting min. HUF 25 000 (approx. EUR 70) on the account and (b) not to withdraw its investment for 3 or 5 consecutive years. In such case, the private individual shall report to the Hungarian tax authority that is has concluded such agreement with a foreign entity.

3. Investors other than Private Individuals

The income of Hungarian tax resident corporate investors arising from the acquisition, holding, redemption or sale of the shares/units is subject to corporate income tax in Hungary at the rate of 9 per cent in accordance with the provisions of the CIT Act.

IV. Impact of a Double Tax Treaty between Hungary and the Jurisdiction of the fund

Where the private individual or corporate investor is subject to tax in Hungary in relation to the shares/units, the provisions of the double tax treaty in force between Hungary and the jurisdiction of the Fund shall be observed. Such provisions may decrease the amount of or eliminate the payable tax in Hungary or the other country. In the case of absence of such double tax treaty, the Hungarian tax laws provide for, in general, a limited deduction of the tax paid abroad from the tax payable in Hungary.

V. Withholding tax

Under Hungarian tax law currently in force, no Hungarian withholding tax is applicable to interest paid on the shares/units by the fund to non-Hungarian tax resident corporate investors.

Hungary applies withholding tax to non-Hungarian tax resident private individuals, however according to the PIT Act, their income from the shares/units should not be subject to tax in Hungary (please see above in Section 1.2(a)).

VI. Financial transactional tax

Under Government Decree 197/2022. (VI. 4.), financial transactional tax shall be payable on the purchase of securities having an ISIN number issued by KELER Central Depository Ltd., the Hungarian central depository, to a client account or own account by an investment enterprise under Act CXXXVIII of 2007 on Investment Firms and Commodity Dealers, and on the Regulations Governing their Activities or credit institution under Act CCXXXVII of 2013 on Credit Institutions and Financial Enterprises. The rate of tax is 0.3% of the value of the securities credited on the client account (securities account) limited to HUF 10,000. The tax is payable by the investment enterprise or credit institution.

In accordance with articles 173 and 174 of the Government Emergency Ordinance no. 32/2012 on undertakings for collective investment in transferable securities and investment management companies and amending and supplementing Capital Market Law No. 297/2004, as further amended ("GEO no. 32/2012"), the Romanian Financial Supervisory Authority ("Autoritatea de Supraveghere Financiara") has been notified of the intention to publicly distribute share/unit classes of investment fund in Romania and such distribution is authorised to take place from the end of the notification procedure.

The Depositary of the investment fund is CACEIS Bank, Luxembourg Branch, with its registered office at 5, Allée Scheffer, L-2520 Luxembourg.

UniCredit Bank S.A., with its registered office at Bd. Expozitiei Nr.1F, Sect 1, Bucharest, Postal Code 012101, Romania, has been appointed as paying and information agent in Romania pursuant to GEO no. 32/2012 (the "Romanian Paying and Information Agent").

Requests for issuance, redemption and conversion of shares/units can be submitted to the Romania Paying and Information Agent at its branch offices or, through its internet banking platform, to the extent it offers this possibility to investors. Redemption proceeds, distributions (if any) and any other payments can be made to the investors via the Romanian Paying and Information Agent.

The issue and redemption prices are published online every trading day at www.structuredinvest.lu  and on the website of the Romanian Paying and Information Agent at www.unicredit.ro/

Read the prospectus and the PRIIPS KID, as provided for by article 98 of GEO no. 32/2012, before investing in investment fund.

The following documents are available in hard copy free of charge from the Romanian Paying and Information Agent and on its website at www.unicredit.ro/:

• The prospectus and the PRIIPS KID
• The articles of incorporation
• The current annual report and, if published, the current semi-annual report
• All the documents listed in the fund’s prospectus

Alpha Bank S.A., with its registered office at 40, Stadiou Street, 10564 Athens, Greece has been appointed as paying agent and distributor pursuant to the Hellenic Capital Market Commission ("HCMC") Board Decision 15/966/30.9.2022.

In accordance with Article 138 of the Investment Funds and Management Companies Act (Zakon o investicijskih skladih in družbah za upravljanje; Official Gazette of the Republic of Slovenia, no. 31/15, as amended) (“ZISDU-3”), the Securities Market Agency (Agencija za trg vrednostnih papirjev) ("ATVP") has been notified of the intention to publicly distribute share/unit classes of the fund in Slovenia and such distribution is authorised to take place from the date CSSF informs the management company that the notification document referred to in Article 4 of Regulation 584/2010/EU has been transmitted to ATVP.

Based on Article 9 of the Decision on the Method and Conditions for Marketing Investment Fund Units (Sklep o načinu in pogojih za trženje enot investicijskih skladov), the following supplement is intended for Slovenian investors:

Facilities for procedures and payment transactions

The paying agent in the Republic of Slovenia providing facilities regarding subscriptions, repurchase and redemption orders, and other payments to unit-holders pursuant to Point 1 of Paragraph 1 of Article 137 of ZISDU-3 is UniCredit Banka Slovenija d.d..

UniCredit Banka Slovenija d.d. having its registered office at Ameriška ulica 2, SI-1000 Ljubljana, Slovenija, acts as the Distributor for Slovenian investors, and is authorised to receive subscription, redemption, and conversion orders. Redemption proceeds, any distributions and payments to Slovenian investors are made through UniCredit Banka Slovenija d.d..

The subscription point is physically only located in the branches of UniCredit Banka Slovenija d.d..

Access to prospectus and PRIIPS KID

The prospectus, fund rules or articles of association, the PRIIPs KIDs and the fund's annual and semi-annual reports are available at www.structuredinvest.lu, and a printed copy of these documents may be obtained by the investor free of charge.
 

Publication of the fund’s asset value and relevant information

Information on the value of the fund shares/units will be published daily at www.structuredinvest.lu.

Important legal and business developments concerning the operations of the fund will be published on www.structuredinvest.lu.
 

Procedures for handling investor complaints and rights

UniCredit Banka Slovenija d.d. is responsible for facilitating information processing and providing access to the procedures and methods of processing complaints for investors' exercise of the rights relating to their investment in the funds in Slovenia.
 

Taxation in Slovenia

1. Resident investors

1.1 Legal persons

According to the Corporate Income Tax Act (Zakon o davku od dohodkov pravnih oseb; Official Gazette of the Republic of Slovenia No. 117/06, as amended) (“ZDDPO-2”), resident legal entities are liable for tax on all income sourced both within and outside the Republic of Slovenia. A resident is defined as an entity with its registered office in the Republic of Slovenia, or an entity without a registered office in Slovenia but having its place of actual management there.

Income from the redemption of an investment fund share/unit or from the payment of a proportionate part of the liquidation estate during the liquidation of an investment fund is considered the income of a legal entity. The tax base is the profit determined in accordance with the provisions of ZDDPO-2.

The general corporate income tax rate, according to ZDDPO-2, is 19%. However, per Article 64 of the Act on Reconstruction, Development and Provision of Financial Assets (Zakon o obnovi, razvoju in zagotavljanju finančnih sredstev; Official Gazette of the Republic of Slovenia No. 131/23), the tax rate for the years 2024 through 2028 is 22%.

1.2 Natural persons

According to the Personal Income Tax Act (Zakon o dohodnini; Official Journal of the Republic of Slovenia, No. 13/11, as amended) (“ZDoh-2”), resident natural persons are liable for income tax on all income sourced both within and outside Slovenia. Per Article 93 of ZDoh-2, an investment coupon is considered capital. Therefore, income from its sale, i.e. the redemption of an investment fund unit, or payment of a proportionate part of the liquidation estate during the liquidation of an investment fund, is taxed under the capital gains rules of ZDoh-2.

The tax base is determined based on the difference between the capital value at the time of disposal and the time of acquisition.

If this difference is positive, the tax base is calculated by subtracting standardized costs related to the acquisition and disposal of the capital from the respective difference. The standardized costs related to the acquisition and disposal of the capital are recognized up to a maximum amount, which must not exceed the lower of a) the sum of 1% of the acquisition capital value and 1% of the disposal capital value, or b) the positive difference between the disposal capital value and the acquisition capital value.

If the difference between the capital value at the time of disposal and the time of acquisition is negative, this loss can be used to offset the positive tax base for capital gains in the year for which income tax is assessed, however, only up to the amount of the positive tax base.

Personal income tax is calculated and paid on this tax base at a rate of 25%. Capital gains are taxed on a ceded basis, meaning they are not included in the annual personal income tax return. The personal income tax rate reduces with the duration of holding a sub-fund unit as follows:

• after five years: 20%;
• after ten years: 15%; and
• after 15 years, the investor is exempt from capital gains taxation.

In the event of a transfer between sub-funds, Article 100 of ZDoh-2 provides for the postponement of the assessment of tax liability.

2. Non-resident investors

Non-resident natural persons are subject to personal income tax on capital gains only with respect to income with a source in Slovenia.

Non-resident legal entities are liable for tax on income earned in or through a business unit in Slovenia, and on income sourced in Slovenia for which a withholding tax obligation is established. They must also comply with the tax regulations applicable in their respective countries of taxation.

3. Disclaimer

This summary of taxation in Slovenia is for informational purposes only and does not constitute tax advice. Before investing, every investor should consult with a tax advisor regarding potential tax consequences, including the validity and effect of tax regulations in Slovenia or any other country, as well as any proposed changes to tax regulations that may be pending at the time of the prospectus.

All investors should note that the effective amount of taxation arising from holding sub-fund shares/units, payment of the redemption value of sub-fund shares/units, or other related circumstances depends on the individual tax position of each unit-holder.

This summary is based on current tax rules. Subsequent changes in the law or changes in its application may affect the correctness of this tax information.

Pursuant to Article 137 of the Act on Open-Ended Investment Funds with Public Offering (Cro. Zakon o otvorenim investicijskim fondovima s javnim ponudom Official Gazzete no. 44/2016, 126/2019, 110/2021, 76/2022, 152/2024) (the “ZOIF”), the trading of units in UCTIS funds in Croatia shall be preceded by the notification to Croatian Financial Services Supervisory Agency (“HANFA”), by the competent authority of the fund’s home member state.

The notification shall include information on the agreed conditions for trading the units of a UCITS fund established in another EU member state in the Republic of Croatia, data required for invoicing or information on applicable regulatory fees or other charges of HANFA, including the address of the management company, information on the systems for performing the tasks referred to in Article 138 paragraphs (1) - (3) of ZOIF, and the data set out in Annex I of Commission Regulation (EU) No. 584/2010, as well as the following annexes for each UCITS fund established in another EU member state whose units are intended to be marketed in the Republic of Croatia:

a.    the current prospectus;

b.    the UCITS fund rules or other relevant document;

c.    the latest audited annual reports and any subsequent semi-annual reports, if available;

d.    the key investor information;

e.    confirmation from the competent authority of the home member state of the UCITS fund, in accordance with Annex II of Commission Regulation (EU) No. 584/2010.

Management company may commence the trading of units of the UCITS fund which was established in another EU member state in the Republic of Croatia, after receiving a notification from the competent authority of the home EU member state of the UCITS fund, confirming that it has forwarded to HANFA the notification with the complete documentation referred to in Article 4 of Commission Regulation No. 584/2010.
 

1 – Conditions for trading

Pursuant to Croatian law, units of a UCITS funds which was established in another EU member state may be traded in the Republic of Croatia, by:

a.    a management company from the Republic of Croatia and a;

b.    management company from another EU member state (the home member state of the UCITS fund) that has been authorized to manage that UCITS fund by the competent authority of the EU member state of the UCITS fund, pursuant to the legislation transposing the Directive 2009/65/EC into the jurisdiction of the home EU member state of the UCITS fund.

The management company is not required to have a physical representative or appoint a third party in the Republic of Croatia to perform the tasks.

Pursuant to Article 138 paragraphs (1) – (3) of the ZOIF, in order to trade units of a UCITS fund established in another EU member state, the Structured Invest S.A., 8-10 rue de Jean Monnet, L-2189 Luxembourg (hereinafter: “management company”) will ensure in the Republic of Croatia the systems necessary for performing the following tasks:

a.    execution of requests for the subscription and redemption of fund units and facilitation of other payments related to UCITS fund units for unit-holders, in the manner provided for in the UCITS fund’s prospectus;

b.    provision of information to investors regarding the available methods for submitting requests for the subscription or redemption of fund units, as well as methods of payment upon redemption requests;

c.    facilitation of the handling of information and access to procedures and measures related to the resolution of investor complaints and the exercise of investor rights arising from their investment in the UCITS fund, in accordance with Articles 63 and 64 of ZOIF;

d.    making available to investors, for viewing and copying, the information and documents referred to in Article 139 paragraph (2), points (1) – (4) of ZOIF, in the manner prescribed by Article 139 paragraphs (3) and (4) of ZOIF.

Moreover, as stipulated under Croatian law, the management company:

a.    will provide the above information to investors, upon request, on a durable medium;

b.    shall act as the contact point for communication with HANFA.

The systems for performing these tasks, which may be electronic, will be ensured in the Republic of Croatia in accordance with Croatian law:

a.    in Croatian or English,

b.    independently and/or through a third party who, in the EU member state, is subject to special regulations governing the performance of such tasks or supervision thereof.
 

2 - Delivery of documents and reports to investors

As stipulated under Croatian law, management company and any person distributing UCITS fund units on its behalf will provide the investor, free of charge and prior to the conclusion of the investment contract, with the key investor information, which include:

a.    identification of the UCITS fund, the management company, and their respective competent authorities;

b.    a brief description of the investment objectives and strategy of the UCITS fund;

c.    a presentation of past performance of the UCITS fund;

d.    a description of the risks associated with investing in the specific UCITS fund, including appropriate guidelines and warnings;

e.    the costs and other fees payable by the UCITS fund or the investor;

f.     for structured UCITS funds referred to in Article 36(1) of Commission Regulation No. 583/2010, a simulation of future performance;

g.    practical information for investors;

h.    precise information on where and how to obtain additional information about the proposed investment, including, but not limited to, information on where and how to obtain, free of charge, the prospectus and the UCITS fund’s semi-annual and audited annual reports, and in which language such information is available to investors;

i.     a statement that details of the current remuneration policy—including the method of calculating remuneration, the identity of the persons responsible for awarding remuneration, and the composition of the remuneration committee, if such committee exists—are available on the management company’s website (including a hyperlink to that website), and that a paper copy of the remuneration policy will be provided to the investor free of charge upon request.

Moreover, the key investor information will be regularly updated and the management company shall also deliver to investors other publications and notices as required by ZOIF.

Finally, at all trading locations, investors will be able to access the prospectus and the latest audited annual and semi-annual reports of the UCITS fund. The management company will, upon the investor’s request, provide the prospectus and key investor information document free of charge, either in printed form, on a durable medium other than paper, or via the management company’s website.
 

3 - Language of documentation

As stipulated under Croatian law, key investor information documents for UCITS funds from another EU member state will be available to investors in the Republic of Croatia in Croatian.

In addition, other documents and information relating to UCITS funds from another EU member state will be available or delivered to investors in the Republic of Croatia in either Croatian or English.
 

4 - Advertising

Advertising of UCITS funds whose units are marketed in the Republic of Croatia is permitted in the Republic of Croatia.

As stipulated under Croatian law, management company:

a.    will ensure that promotional content of a UCITS fund, which it prepares or approves for further distribution, complies with the requirements of Article 4 of Regulation (EU) 2019/1156;

b.    will prepare promotional content for advertising UCITS funds in the Republic of Croatia in Croatian language;

c.    is responsible for the completeness and accuracy of any information it prepares or approves for further distribution that is published for the purpose of promoting the UCITS fund.
 

5 – Tax considerations

The tax treatment of investments in UCITS fund may is subject to the laws of the Republic of Croatia.

Investors are advised to consult their tax advisor to understand the specific implications for their individual circumstances.

Notification

The Polish rules and regulations regarding marketing carried out by foreign UCITS in Poland are primarily set out in Section XII of the Polish Act of 27 May 2004 on Investment Funds and Management of Alternative Investment Funds ("IFA").

Pursuant to Article 253 of the IFA, foreign UCITS may market its shares/units in the Republic of Poland, provided that the Polish Financial Supervisory Authority ("KNF") obtains, from the competent authorities of the home Member State of the foreign UCITS, a notification of the intention to market shares/units of the foreign UCITS in the Republic of Poland.

The shares/units of a foreign UCITS may be marketed in the Republic of Poland after the foreign UCITS is informed by the competent authorities of its home Member State that the KNF has been duly notified.

Such notification shall include:

(1)  a detailed description of marketing methods in the Republic of Poland for shares/units issued by a foreign UCITS, including principles and conditions of payments to and from the fund in relation to the acquisition and redemption of shares/units, and the manner in which information about the fund will be provided;

(2)  name and surname or business name and the place of residence or registered office and address in the Republic of Poland of the representative of the foreign UCITS in the territory of the Republic of Poland - if they are appointed by the foreign UCITS;

(3)  business name and registered office and address of the paying agent of the foreign UCITS in the territory of the Republic of Poland - if they are appointed by the foreign UCITS;

(4)  the contents of additional information for investors acquiring units in the Republic of Poland; and

(5)  information required for the KNF to issue a document confirming payment by the foreign UCITS of the fee for entry into the register maintained by the KNF or information required for the KNF to provide information about the fees payable to the KNF by the foreign UCITS.

The notification shall be accompanied by:

(1)  rules of procedure of the foreign UCITS;

(2)  prospectus of the foreign UCITS;

(3)  key information - if the foreign UCITS renders key information available to all investors;

(4)  key information and key investor information - if the foreign UCITS renders key investor information available to investors other than retail investors

(5)  key investor information - in the event that the foreign UCITS markets shares/units exclusively to investors other than retail investors and provides key investor information to such investors

(6)  most recent annual and semi-annual financial statements of the foreign fund, if drawn up; and

(7)  a certificate issued by competent authorities of the home Member State of the foreign fund, confirming that the foreign fund acts in line with the EU law regulating collective investments in securities (UCITS).

The notification and the documents attached to it should be drawn up in or translated into Polish or English, but the contents of additional investor information, key information, and key investor information should be drawn up in or translated into Polish.

Information obligations

Pursuant to Article 254 of the IFA, a foreign UCITS is obliged to:

(1)  publish, in the territory of the Republic of Poland:

a.    rules of procedure, information prospectus, additional information for investors and:

                                      i.    key information - if this fund renders key information available to all investors, or

                                     ii.    key information and key investor information - if this fund renders key investor information available to investors other than retail investors, or

                                    iii.    key investor information - in the event that the fund disposes participation titles exclusively to investors other than retail investors and provides key investor information to such investors,

b.    changes made to the information prospectus, additional information for investors, key information, or key investor information,

c.    annual and semi-annual financial statements;

(2)  render available when marketing shares/units:

a.    key information - in the case of retail investors and investors other than retail investors, if the foreign UCITS renders key information available to investors other than retail investors,

b.    key investor information - in the case of investors other than retail investors, if the foreign UCITS does not render key information available to such investors,

c.    additional information for investors,

d.    other information and documents it is obliged to render available in accordance with law regulations applicable in the home Member State

- in such a way as to render it possible to familiarise oneself with them before purchasing the shares/units.

The above-mentioned documents and information shall be published by the foreign UCITS in the Republic of Poland on the Polish webpage of the foreign UCITS.

The additional information for investors shall include:

(1)  basic information on the disposal and redemption of shares/units in the territory of the Republic of Poland, including the list of entities intermediating in the disposal and redemption of shares/units of the foreign UCITS;

(2)  a brief description of tax liabilities of the holders of shares/units of the foreign UCITS;

(3)  an indication of the Polish website of the foreign UCITS where the fund shall make available information and documents for the shares/unit holders of the foreign UCITS in the territory of the Republic of Poland;

(4)  a designation of a representative of the foreign UCITS or a paying agent of the foreign UCITS, together with a brief description of their function - if appointed by the foreign UCITS, and if the foreign UCITS has not appointed a representative of the foreign UCITS - an indication of the manner in which complaints are lodged by the participants of the foreign UCITS and the manner in which information about the fund is made available to the participants of the foreign UCITS.

The time frame for publication, in the territory of the Republic of Poland, of the changes in the information prospectus, key information, key investor information, and rules of procedure of a foreign UCITS, and the time frame for their entry into force in relation to the share/unit holders of the foreign UCITS in the Republic of Poland, shall be set in accordance with law regulations of the home Member State of the fund. The timeframes correspond, respectively, to the time frame for publication of the changes in the home Member State of the fund and the time frame for their entry into force in relation to the share/unit holders of the fund in that State.

In the Republic of Poland:

(1)  key information, key investor information and additional investor information published and rendered available should be drawn up in or translated into Polish;

(2)  other documents and information subject to publication or disclosure obligation should be drawn up or translated into Polish or English.

At the request of a share/unit-holder, a foreign UCITS or its management company shall provide additional information, in the Polish language, concerning the fund's investment limits, the methods for managing the fund's investment risks, as well as current changes and increases in the value of the fund's key investments.

The disposal and redemption price of the shares/units of a foreign fund shall be published with the frequency provided for in law regulation of the home Member State of the foreign fund.

Obligations of the foreign UCITS regarding facilities and protection of the participants

Pursuant to Article 256 of IFA, the foreign UCITS shall be obliged to establish, for the purposes of the activity consisting in the marketing of shares/units issued by that fund in the territory of the Republic of Poland, adequate technical and organisational solutions ensuring:

(1)  the proper disposal and redemption of shares/units of the foreign UCITS in the territory of the Republic of Poland on terms and conditions set out in the notification referred to in Article 253 (1) of the IFA, including efficient depositing and payment of amounts related to the acquisition and redemption of shares/units and payment of profits or other benefits due to participants of the foreign UCITS;

(2)  access by participants and potential participants of the foreign UCITS to information on the disposal and redemption of shares/units issued by the foreign UCITS in the territory of the Republic of Poland and the manner in which amounts related to the redemption of units are paid out;

(3)  ability for participants of the foreign UCITS to exercise rights related to the investment in shares/units, including to file complaints, and easy access to procedures and information related to the exercise of rights related to investment in shares/units by participants and potential participants of the foreign UCITS, including procedures and information related to measures applied in the complaint handling process;

(4)  access by participants and potential participants of the foreign UCITS to documents and information referred to in Article 254 (1) of the IFA as well as information on the price of disposal and redemption of shares/units of the foreign UCITS, in a way that enables them to examine them and make copies, in accordance with the requirements referred to in Article 254 (1b-5) of the IFA;

(5)  that participants and potential participants of the foreign UCITS are provided with information on the obligations of the foreign UCITS that are being fulfilled through implemented technical and organisational solutions, on a durable medium; and

(6)  the exchange of information between the PFSA and the foreign UCITS.

In addition, the foreign UCITS is under an obligation to:

(1)  pursue activities in the territory of the Republic of Poland in accordance with the principles of fair trading;

(2)  ensure that participants of the foreign UCITS are provided with at least the same level of security as in the home Member State;

(3)  provide participants of the foreign UCITS with confirmations of disposal or redemption of shares/units in the Polish language, with the frequency applicable to the foreign UCITS in accordance with legal regulations of the home Member State;

(4)  ensure that the translation of information and documents listed in Article 254 (1) of the IFA exactly matches the contents of original information.

Tax considerations

The tax treatment of investments in UCITS funds is subject to the laws of the Republic of Poland.

Income derived from such investments may be classified as capital gains arising from the disposal of fund shares/units, which are generally subject to Personal Income Tax or Corporate Income Tax, as applicable. When calculating the capital gain, the taxable amount may be reduced by the eligible acquisition costs. The flat tax rate applicable to capital gains is 19%.

In certain circumstances, individuals may also be subject to a solidarity tax at the rate of 4% on the portion of income (including capital gains) exceeding PLN 1,000,000.

Investors are strongly advised to consult with their professional tax adviser to determine the specific tax implications applicable to their individual circumstances.