Registered as a securitization fund, Fermion Equity Fund is managed by Fermion Capital Sàrl. Fermion Capital exists as a direct consequence of Luxembourg’s Securitization Law of March 22, 2004, which outlines taxation requirements for a securitization company. Securitization companies based in Luxembourg are subject to taxation as if they were corporate entities. That places the effective tax rate for securitization vehicles at 29.22 percent, which consists of a 21 percent tax rate on income exceeding 15,000 euros, a Solidarity Surtax of seven percent and a Municipal Business tax rate of 6.75 percent. The tax rate can be reduced via obligations arising from payments to investors in the vehicles such as interest or dividends. However, as long as a securitization company in Luxembourg does not require a trade license, and its securities, assets, and bank balance exceed 90 percent of its balance sheet total, it is only subject to the minimum corporate taxation of 3,000 euros plus the Solidarity Surtax. Luxembourg’s double taxation agreements also benefit funds established within it; for instance, the securitization company is not liable to net wealth tax nor withholding tax on distributions to investors.

1. Fermion Capital

2. Registered as a securitization fund, Fermion Equity Fund is managed by
Fermion Capital Sàrl. Fermion Capital exists as a direct consequence of
Luxembourg’s Securitization Law of March 22, 2004, which outlines taxation
requirements for a securitization company.

3. Securitization companies based in Luxembourg are subject to taxation as if
they were corporate entities.That places the effective tax rate for securitization
vehicles at 29.22 percent, which consists of a 21 percent tax rate on income
exceeding 15,000 euros, a Solidarity Surtax of seven percent and a Municipal
Business tax rate of 6.75 percent.The tax rate can be reduced via obligations
arising from payments to investors in the vehicles such as interest or dividends.

4. However, as long as a securitization company in Luxembourg does not require a
trade license, and its securities, assets, and bank balance exceed 90 percent of
its balance sheet total, it is only subject to the minimum corporate taxation of
3,000 euros plus the Solidarity Surtax. Luxembourg’s double taxation
agreements also benefit funds established within it; for instance, the
securitization company is not liable to net wealth tax nor withholding tax on
distributions to investors.