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This summary also does not tackle the tax implications that may possibly be suitable to holders in distinctive tax cases such as, without limitation, dealers in securities, traders that elect to use a mark-to-market technique of accounting, holders that possess our ordinary shares as part of a "straddle," "hedge," "conversion transaction," or other built-in expense, financial institutions or other economical institutions, personal retirement accounts and other tax-deferred accounts, insurance 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 normal shares is a resident of Luxembourg for inheritance tax reasons at the time of his or her death, our standard shares are bundled in his or her taxable foundation for inheritance tax reasons. On the opposite, no inheritance tax is levied on the transfer of our regular shares on the dying of an individual holder in circumstances the place the deceased was not a resident of Luxembourg for inheritance purposes. Holders of our ordinary shares who are both (i) an undertaking for collective investment governed by the amended legislation of December 17, 2010, (ii) a specialised expenditure fund ruled by the amended legislation of February 13, 2007, (iii) a relatives prosperity administration business ruled by the amended law of May 11, 2007, or (iv) a reserved substitute expense fund dealt with as a specialized financial commitment fund for Luxembourg tax purposes governed by the regulation of July 23, 2016, are exempt from profits tax in Luxembourg

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