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Specific information and documents available to investors in certain countries

Date: 9 January 2025

 

Passporting overview of Structured Invest’s UCITS funds 

Fund Austria Bulgaria Czech Republic Germany Greece Hungary Luxembourg Italy Romania Slovakia
onemarkets SICAV X X X X X X X X X X

Germany

Paying and Information Agent in Germany

The bank CACEIS Bank S.A. Germany Branch, Lilienthalallee 36, D-80939 Munich has assumed the function of Paying and Information Agent as defined in Section 309 KAGB in Germany (the "German Paying and Information Agent") for funds distributed in Germany. The German Paying and Information Agent accepts subscription, conversion and redemption orders.

Redemption proceeds, any distributions, and payments to the investors may be made through the German Paying and Information Agent.

The following documents are available free of charge from the German Paying and Information Agent:

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

Information for investors is published to the extent required by law in the Federal Republic of Germany, in the online version of the Bundesanzeiger. The issue and redemption prices are published online every trading day at www.structuredinvest.lu and can be obtained free of charge from the German Paying and Information Agent.

Tax notice for Germany

The following information on the taxation of income from fund units is of a general nature, is limited to the investment funds listed in the prospectus of the fund and relates to investors with unlimited tax liability in Germany who hold their fund units as private assets or business assets.

This information must not be understood as tax advice and does not replace such advice. The information is based on the current legal situation as it results from tax legislation and administrative regulations and their interpretation or supplementation by the tax authorities and court rulings. Subsequent changes to the legal situation may also be introduced retroactively and adversely affect the tax consequences described below. This summary does not claim to deal with all tax aspects that may be of significance for taxation due to the personal circumstances of the individual investor. Individual investors are therefore advised to seek advice from their tax advisor, if necessary, on the consequences of acquiring, holding or disposing of the fund units.

As special-purpose assets, the fund is generally exempt from corporation and trade tax in Germany. However, it is partially liable to corporation tax on its domestic (i.e. German) investment income and other domestic income within the meaning of the limited income tax liability, with the exception of gains from the sale of shares in corporations. The tax rate is 15%. Insofar as the taxable income is collected by way of withholding taxes, the 15% tax rate already includes the solidarity surcharge. However, the investment income is subject to income tax for the private investor as income from capital assets, insofar as it exceeds, together with other investment income, the annual lump-sum savings amount of EUR 1,000 (for single persons or married couples assessed separately) or EUR 2,000 (for married couples assessed jointly). Income from capital assets is generally subject to a tax deduction of 25% (plus solidarity surcharge and church tax, if applicable).

Under certain conditions, investors may receive a lump-sum portion of this investment income tax-free (so-called partial exemption). A partial exemption is applicable to income from investment funds that meet the tax requirements for classification as equity funds or mixed funds. Equity funds are investment funds that, in accordance with the investment terms and conditions, continuously invest more than 50% of the value of their assets in equity investments as defined by the Investment Tax Act. Mixed funds are investment funds that, in accordance with the investment conditions, continuously invest at least 25% of the value of their assets in equity investments within the meaning of the Investment Tax Act. If the investment fund does not meet the tax requirements for either an equity fund or a mixed fund, no partial exemptions are applicable to the investment income. If the tax classification of the investment fund for the purposes of the partial exemption changes, the fund unit is deemed to have been sold and to have been acquired on the following date with a new tax classification for the purposes of the partial exemption; however, any resulting notional capital gain is not to be taken into account until the fund units are actually sold.

Income from capital assets also includes income from investment funds (investment income), i.e. the distributions of the investment fund, the advance lump sums and the gains from the sale of the fund units. In principle, if the fund units are held in a domestic, i.e. German, securities account, the tax deduction made by the German depositary institution has a settlement effect for the private investor (so-called final withholding tax), so that the income from capital assets regularly does not have to be declared in the income tax return. When the tax is withheld, the German depositary institution generally already offsets losses and credits foreign withholding taxes arising from the direct investment. However, the tax deduction has no settlement effect if, among other things, the personal tax rate is lower than the settlement rate of 25% and the so-called favourable tax assessment is applied for. In this case, the income from capital assets must be declared in the income tax return. The tax office then applies the lower personal tax rate and credits the tax deduction made against the personal tax liability. If income from capital assets has not been subject to a tax deduction (e.g. because a profit was generated from the sale of fund units in a foreign securities account), this must always be stated in the income tax return. In the context of the assessment, this income from capital assets is then also subject to the flat tax rate of 25% or, in case of the favourable tax assessment applies, the lower personal tax rate. If the fund units are held as business assets, the investment income is recognised for tax purposes as business income.

I. Fund units held as private assets (tax residents)

Distributions

Distributions by the fund are generally taxable. If the fund meets the tax requirements for a partial exemption, distributions may be partially tax-free. However, if the fund meets the tax requirements for an equity fund, 30% of the distributions are tax-free. If the fund meets the tax requirements for a mixed fund, 15% of the distributions are tax-free. The taxable distributions are generally subject to a 25% withholding tax (plus solidarity surcharge and church tax, if applicable). Tax withholding may be waived if the investor is a German tax resident and submits an exemption form, provided that the taxable income does not exceed EUR 1,000 for single taxpayers or EUR 2,000 for married couples filing jointly. The same also applies if a certificate is presented for persons who are not expected to be assessed for income tax (so-called non-assessment certificate, hereinafter "NV-certificate"). If the domestic investor holds the fund units in a domestic custody account, the depositary institution as paying agent shall refrain from deducting tax if it is presented, prior to the specified distribution date, with an exemption order issued in a sufficient amount in accordance with an official model or a NV-certificate issued by the tax office for a maximum period of three years. In this case, the investor is credited the entire distribution without deduction.

At the level of business investors, distributions by the fund are generally subject to income tax or corporate income tax and trade tax.

If the fund meets the tax requirements for an equity fund, 60% of the distributions are tax-free for income tax purposes and 30% for trade tax purposes if the fund units are held by individuals as business assets. For taxable corporations, generally 80% of the distributions are tax-exempt for corporate income tax purposes and 40% are tax-exempt for trade tax purposes. For corporations that are life or health insurance companies and for which the fund units are classified as investments, or that are credit institutions and for which the fund units are classified as part of the trading book or were acquired by them with the aim of achieving a short-term proprietary trading profit, 30% of the distributions are tax-free for corporate income tax purposes and 15% for trade tax purposes.

If the fund meets the tax requirements for a mixed fund, 30% of the distributions are tax-free for income tax purposes and 15% for trade tax purposes if the fund units are held by individuals as business assets. For taxable corporations, generally 40% of the distributions are tax-exempt for purposes of corporate income tax and 20% for purposes of trade tax. For corporations that are life or health insurance companies and for which the fund units are classified as investments, or that are credit institutions and for which the fund units are classified as part of the trading book or were acquired for the purpose of achieving a short-term proprietary trading profit, 15% of the distributions are tax-exempt for corporate income tax purposes and 7.5% for trade tax purposes.

For tax deduction purposes, if the tax requirements for an equity or mixed fund are met, the partial exemption rate applicable to private investors is applied uniformly, i.e. 30% in the case of an equity fund and 15% in the case of a mixed fund.

Advance lump sums

The advance lump sum is the amount by which the fund's distributions within a calendar year fall short of the base yield for that calendar year. The base yield is determined by multiplying the fund unit's redemption price at the beginning of a calendar year by 70% of the prime rate derived from the long-term attainable yield on public bonds. The base yield is limited to the additional amount that results between the first and the last redemption price set in the calendar year plus distributions within the calendar year. In the year in which the fund units are acquired, the advance lump sum shall be reduced by one-twelfth for each full month preceding the month of acquisition. The advance lump sum is deemed to have accrued on the first working day of the following calendar year. Advance lump sums are generally taxable.

If the fund meets the tax requirements for a partial exemption, advance lump sums may be partially tax-exempt. The taxable advance lump sums are generally subject to a tax deduction of 25% (plus solidarity surcharge and church tax, if applicable). The tax deduction may be waived if the investor is a tax resident and submits an exemption order, provided that the taxable income components do not exceed EUR 1,000 in the case of single tax assessment or EUR 2,000 in the case of joint tax assessment of married couples. The same also applies if a NV-certificate is presented for persons who are not expected to be assessed for income tax.

If the domestic investor holds the fund units in a domestic custody account, the depositary institution as paying agent shall refrain from deducting tax if it is presented, prior to the time of inflow, with an exemption order issued in a sufficient amount in accordance with an official model or a NV-certificate issued by the tax office for a maximum period of three years. In this case, no tax is withheld. Otherwise, the investor must provide the domestic custodian with the amount of tax to be withheld. For this purpose, the depositary institution may collect the amount of tax to be withheld from an account maintained with it and in the name of the investor without the investor's consent. Unless the investor objects prior to the inflow of the advance lump sum, the custodian may collect the amount of tax to be withheld from an account in the name of the investor to the extent that an overdraft facility agreed with the investor for this account has not been utilised. If the investor fails to fulfill his obligation to provide the amount of tax to be withheld to the domestic depositary institution, the depositary institution shall notify the tax office responsible for it. In this case, the investor must declare the advance lump sum in his income tax return.

Capital gains at investor level.

If fund units are sold, the capital gain is subject to a 25% withholding tax. If the fund meets the tax requirements for an equity fund for partial exemption purposes, 30% of the capital gains are tax-free. Equity funds are investment funds that continuously invest more than 50% of their value or assets in equity investments according to their investment conditions. If the fund meets the tax requirements for a mixed fund for partial exemption purposes, 15% of the capital gains are tax-free. Mixed funds are investment funds that continuously invest at least 25% of their value or assets in equity investments according to their investment conditions. If the fund does not meet the tax requirements for either an equity or mixed fund, no partial exemption applies to the capital gains.

If the fund units are held in a domestic custody account, the custodian will make the tax deduction, taking into account any partial exemptions. The 25% withholding tax (plus solidarity surcharge and, if applicable, church tax) can be avoided by submitting a sufficient exemption instruction or a NV-certificate. If such fund units are sold by a private investor at a loss, the loss can be offset against other positive income from capital assets. If the fund units are held in a domestic custody account and positive income from capital assets was generated at the same custodian in the same calendar year, the custodian will offset the loss. When determining the capital gain, the gain must be reduced by the advance lump sums recognised during the period of ownership.

II. Fund units held as business assets (resident for tax purposes)

Refund of the fund's corporate income tax

If the investor is a domestic corporation, association of persons or estate which, according to its articles of association, foundation or other constitution and according to its actual management, exclusively and directly serves charitable, benevolent or ecclesiastical purposes, or a foundation under public law which exclusively and directly serves charitable or benevolent purposes, or a legal entity under public law which exclusively and directly serves ecclesiastical purposes, then, upon application, the investor shall be reimbursed by the fund for the corporation tax incurred at the fund level on a pro rata basis for its holding period; this does not apply if the fund units are held in a commercial business operation. The same applies to comparable foreign investors domiciled and managed in a foreign state providing administrative and recovery assistance. The refund requires that the investor has been the civil law and beneficial owner of the fund units for at least three months prior to the inflow of the fund's income subject to corporate income tax, without any obligation to transfer the fund units to another person. Furthermore, with regard to the corporation tax incurred at the fund level on German dividends and income from German quasi-equity profit participation rights, the refund essentially requires that German shares and German quasi-equity profit participation rights were held by the fund as the beneficial owner for an uninterrupted period of 45 days within 45 days before and after the due date of the investment income and that there was an uninterrupted minimum risk of a change in value of 70% during these 45 days. The application must be accompanied by evidence of tax exemption and a certificate of fund unit ownership issued by the custodian. The fund unit inventory certificate is a certificate issued in accordance with an official model showing the number of fund units held by the investor throughout the calendar year, as well as the time and scope of the acquisition and sale of fund units during the calendar year. Due to the high complexity of the regulation, it seems advisable to consult a tax advisor.

Distributions

Distributions by the fund are generally subject to income or corporation tax and trade tax. If the fund meets the requirements for a partial exemption, distributions may be partially tax-exempt for income or corporation tax and trade tax purposes. Distributions are generally subject to a 25% withholding tax (plus solidarity surcharge). If the fund meets the tax requirements for a partial exemption, the partial exemption rate applicable to private investors is applied uniformly for tax deduction purposes.

Advance lump sums

The advance lump sum is the amount by which the fund's distributions within a calendar year fall short of the base yield for that calendar year. The base yield is determined by multiplying the fund unit's redemption price at the beginning of a calendar year by 70% of the prime rate derived from the long-term attainable yield on public bonds. The base yield is limited to the additional amount that results between the first and the last redemption price set in the calendar year plus distributions within the calendar year. In the year in which the fund units are acquired, the advance lump sum shall be reduced by one-twelfth for each full month preceding the month of acquisition. The advance lump sum is deemed to have accrued on the first working day of the following calendar year. Advance lump-sum payments are generally subject to income tax or corporation tax and trade tax. If the fund meets the requirements for a partial exemption, advance lump sums may be partially tax-exempt for purposes of income or corporate income tax and trade tax. As a rule, the advance lump sums are subject to a 25% tax deduction (plus solidarity surcharge). If the fund meets the tax requirements for a partial exemption, the partial exemption rate applicable to private investors is applied uniformly for tax deduction purposes.

Capital gains at investor level

Gains from the disposal of the fund units are generally subject to income or corporation tax and trade tax. When determining the capital gain, the gain must be reduced by the advance lump sums recognised during the period of ownership. If the fund qualifies for a partial exemption, capital gains may be partially exempt from tax for purposes of income or corporation tax and trade tax. Gains from the sale of fund units are generally not subject to tax withholding.

Negative taxable income

Negative taxable income cannot be attributed directly to the investor.

Liquidation taxation

During the liquidation of the fund, distributions are considered income only to the extent that they include the appreciation of a calendar year.

Overview of the tax consequences for usual operating investor groups

Following the General Section of the Prospectus, you will find a summary overview for common operational investor groups.

III. Non-resident taxpayers

If a non-resident taxpayer holds the fund units in a custody account with a domestic custodian, no tax will be withheld on distributions, advance lump sums, and gains from the sale of the fund units, provided that the non-resident taxpayer can prove his or her non-resident status. If the custodian is not aware of the investor's non-resident status or if proof of such status is not provided in good time, the foreign investor is obliged to apply for a refund of the tax withheld in accordance with the German Fiscal Code (Abgabenordnung). The competent tax office is the tax office responsible for the depositary institution.

IV. Solidarity Surcharge

A solidarity surcharge of 5.5% is levied on the tax withheld on distributions, advance lump sums and gains from the sale of fund units. The solidarity surcharge is creditable against income tax and corporation tax.

V. Church tax

Insofar as the income tax is already levied by a domestic depositary (withholding agent) by way of tax withholding, the church tax payable thereon is regularly levied as a surcharge on the tax withholding in accordance with the church tax rate of the religious community to which the church tax payer belongs. The deductibility of church tax as a special expense is already taken into account as a reduction when the tax is withheld.

VI Foreign withholding tax

In some cases, withholding tax is withheld on the fund's foreign income in the countries of origin. This withholding tax cannot be taken into account by the investors in order to reduce tax.

VII Consequences of a merger of investment funds

In the case of a merger of a domestic investment fund into another domestic investment fund, there is no disclosure of hidden reserves either at the level of the investors or at the level of the investment funds involved, i.e. this process is tax-neutral. The same applies to the transfer of all assets of a domestic investment fund to a domestic investment stock corporation with variable capital or a sub-fund of a domestic investment stock corporation with variable capital. If the investors of the transferring investment fund receive a cash payment provided for in the merger plan, such payment shall be treated as a distribution. The same principles should apply with a view to a merger of a foreign investment fund into another investment fund both of which are subject to the same law of a foreign state providing administrative and recovery assistance (such as, e.g. Luxembourg).

Legal and tax risk

The legal and tax treatment of funds can change in unforeseeable and uncontrollable ways. In the event of a correction that is fundamentally disadvantageous for the investor from a tax perspective, a change in the incorrectly determined tax bases of the fund for previous fiscal years may result in the investor having to bear the tax burden arising from the correction for previous fiscal years, even though he may not have been invested in the investment fund at that time. Conversely, investors may find that they no longer benefit from a correction for the current and previous fiscal years in which they held an investment in the investment fund that is fundamentally advantageous from a tax perspective due to the redemption or sale of the units prior to the implementation of the corresponding correction.

In addition, a correction of tax data may result in taxable income or tax benefits actually being assessed for tax purposes in a different assessment period than the one that is actually applicable and this may have a negative impact on the individual investor.

Right of revocation in accordance with Section 305 KAGB

If investment units are purchased on the basis of verbal negotiations outside of the permanent business premises of the party making or brokering the sale, then the purchaser may revoke his declaration of the sale in writing to the foreign management company within a period of two weeks (right of revocation); this also holds when the party selling or brokering the sale of the units does not have any permanent business premises. For distance selling as defined by Section 312c of the German Civil Code (BGB), there is no right of revocation for the acquisition of financial services whose price is subject to fluctuations on the financial market (Section 312g(2)(8) BGB).

Timely dispatch of the revocation notice is sufficient for the purpose of observing the time limit. The revocation must be declared in writing directly to Structured Invest S.A. 8-10, rue Jean Monnet, L-2180 Luxembourg including information on the person making the declaration and his signature; no reason for the revocation is required.

The deadline for revocation does not commence until a copy of the concluded contract has been delivered to the purchaser or a contract note has been sent to him or her, including instructions regarding the right of the revocation similar to the above.

If the beginning of the period is in dispute, the burden of proof lies with the seller.

The right of revocation does not apply if the seller can prove that either the investor acquired the units as part of his commercial operations or if he called on the investor to conduct negotiations leading to the sale of the units as a result of a previous order in accordance with Section 55(1) of the Industrial Code (GewO).

If the revocation is exercised after the investor has made payment, the foreign management company is obliged to repay the investor’s costs – incrementally as the purchased units are transferred back to the fund, if necessary – in addition to an amount corresponding to the value of the purchased units the day after the revocation was received.

The right of revocation cannot be waived.

Austria

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.

Bulgaria

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.

Czech Republic

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. 

Hungary

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.

Romania

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

Greece

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.

Welcome to Structured Invest

To access the product information and services provided on our website please read and accept the following disclaimer.

Disclaimer more...

Structured Invest Société Anonyme checks and updates the information on its web pages on a permanent basis. Despite our diligent attention, however, the information may have changed since it was posted. Therefore, we cannot be held responsible and we offer no guarantee for the up-to-dateness, accuracy or completeness of the information provided. The same applies to all other web pages to which connection is made via hyperlinks. Structured Invest Société Anonyme is not responsible for the content of the web pages reached via hyperlinks. 

In addition, Structured Invest Société Anonyme reserves the right to make changes or additions to the information provided. 

The content and structure of the web pages of Structured Invest Société Anonyme are protected by copyright. Reproduction of information or data, especially the use of texts, text excerpts or image material, shall require prior consent of Structured Invest Société Anonyme.

The content on our website serves only for informational purposes and does not form the basis of any business relationship. We, Structured Invest Société Anonyme, cannot be held liable in the event of inaccurate, incomplete, or outdated information or in the event of falsification of information. Please speak with one of our advisers before making any business decisions. 

Otherwise, the information on this website concerning securities and financial services was reviewed only in terms of its compatibility with the laws of Luxembourg. In some foreign jurisdictions, the distribution of this type of information may be subject to legal restrictions under certain circumstances. The following information is therefore not addressed to natural or legal persons whose residence or business domicile is subject to a foreign jurisdiction that places restrictions on the distribution of this type of information. 

Consequently, the information on this website does not constitute an offer or solicitation to buy or sell securities to citizens of legal systems or states,

  • where such offers or solicitations are not permitted by law, 
  • where Structured Invest Société Anonyme is not authorized to issue such
    an offer or solicitation, or
  • where said offers or solicitations to residents of the territory in question are illegal,

and it must not be used for such purposes.

In particular, the following information does not constitute an offer or solicitation to British citizens to buy or sell securities, nor is it intended as such. Accordingly, buy and sell orders of British citizens will not be processed.

Any person who accesses these web pages from a legal territory in which the aforementioned restrictions are applicable should obtain information about said restrictions and comply with them accordingly.

The securities mentioned on this web page are not and shall not be registered according to the U.S. Securities Act of 1933 as currently amended, and therefore they cannot be offered or sold in the United States, unless they are not subject to or are exempt from the registration obligation set forth in the U.S. Securities Act.
Thus the securities listed in the following information cannot be transferred to US citizens or to other persons in the United States, unless the respective securities transaction does not require registration under US law.

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