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This summary also does not handle the tax effects that could be appropriate to holders in unique tax scenarios such as, without limitation, dealers in securities, traders that elect to use a mark-to-market process of accounting, holders that individual our standard shares as element of a "straddle," "hedge," "conversion transaction," or other built-in financial investment, banking institutions or other economical institutions, personal retirement accounts and other tax-deferred accounts, insurance coverage corporations, tax-exempt corporations, U.S. Luxembourg Residents Benefiting from a Special Tax Regime. Under Luxembourg tax legislation, exactly where an particular person holder of our common shares is a resident of Luxembourg for inheritance tax reasons at the time of his or her death, our normal shares are bundled in his or her taxable basis for inheritance tax reasons. On the opposite, no inheritance tax is levied on the transfer of our standard shares on the death of an individual holder in circumstances exactly where the deceased was not a resident of Luxembourg for inheritance uses. Holders of our regular shares who are possibly (i) an endeavor for collective investment decision governed by the amended law of December 17, 2010, (ii) a specialized investment fund ruled by the amended law of February 13, 2007, (iii) a loved ones wealth administration organization ruled by the amended law of May 11, 2007, or (iv) a reserved choice expenditure fund dealt with as a specialised expenditure fund for Luxembourg tax applications ruled by the regulation of July 23, 2016, are exempt from revenue tax in Luxembourg

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