TAX. 4.1 The merger may entails tax consequences for each unit-holder. The descriptions in sections 4.2 and 4.3 below relate only to unit-holders subject to Norwegian tax rules. Unit-holders who are tax residents in other jurisdictions than Norway are advised to investigate the applicable tax rules in their respective countries of tax residency .
4.2 The merger, as further described in section 12Error! Reference source not found. below, will be carried out as a cash merger with tax continuity. This means that all rights and obligations in the Norwegian Fund must be real- ised before the Effective Date, and that the unit-holders' tax positions in relation to the units in the Norwegian Fund will be transferred and apportioned pro rata to the units in the Finnish Fund that are issued as merger con- sideration. The realisation of equity positions will be exempt from tax at the fund level under the Norwegian participation exemption. However, the realisation of debt instruments will trigger tax at the fund level for gains with a tax rate of 22%. To prevent the Norwegian Fund's tax obligation from being transferred to the Finnish Fund, a distribution will be made to the unit-holders in the Norwegian Fund prior to the merger, corresponding to the taxable income for the income year, including net gains from the realisation of debt instruments. The distribution will occur in a similar manner to the ordinary distribution of dividends. That is, the distribution will take place in the form of issuance of new units to the unit-holders in the Norwegian Fund. The portion of the distribution and gain that is considered to be related to equities is taxable as capital gains for the unit-holders, while the portion of the distribution and gain s that is considered to be related to debt instruments is taxable for the unit-holders as interest income.
4.3 Except for the tax consequences for the individual unit-holder in the Norwegian Fund as a result of the distribution mentioned in section 4.2 above and any tax consequences that may arise from the payment of a possible cash equalization amount (see further description in section 13.2.1 below), the merger will not have any tax conse- quences for the unit-holders. The merger will not be considered as a taxable realisation for Norwegian tax pur- poses for the unit-holders in the Norwegian Fund.
4.4 The unit-holders who exercise their right to redeem or exchange units without cost before the merger are for Nor- wegian tax purposes consid...
TAX. 4.1 The merger may entails tax consequences for each unit-holder. The descriptions in sections 4.2 and 4.3 below relate only to unit-holders subject to Norwegian tax rules. Unit-holders who are tax residents in other jurisdictions than Norway are advised to investigate the applicable tax rules in their respective countries of tax residency .
4.2 The merger, as further described in section 12 below, will be carried out as a cash merger with tax continuity. This means that all rights and obligations in the Norwegian Fund must be realised before the Effective Date, and that the unit-holders' tax positions in relation to the units in the Norwegian Fund will be transferred and apportioned pro rata to the units in the Finnish Fund that are issued as merger consideration. The reali sation of equity positions will be exempt from tax at the fund level under the Norwegian participation exemption. However, the re- alisation of debt instruments will trigger tax at the fund level for gains with a tax rate of 22%.
4.3 Except for any tax consequences that may arise from the payment of a possible cash equalization amount (see further description in section 13.2.1 below), the merger will not have any tax consequences for the individual unit- holder. The merger will not be considered as a taxable realisation for Norwegian tax purposes for the unit-holders in the Norwegian Fund.
4.4 The unit-holders who exercise their right to redeem or exchange units without cost before the merger are for Nor- wegian tax purposes considered to have realised their units.
TAX. 4.1 The merger may entails tax consequences for each unit-holder. The descriptions in sections 4.2 and 4.3 below relate only to unit-holders subject to Norwegian tax rules. Unit-holders who are tax residents in other jurisdictions than Norway are advised to investigate the applicable tax rules in their respective countries of tax residency .
4.2 The merger, as further described in section 12 below, will be carried out as a cash merger with tax continuity. This means that all rights and obligations in the Norwegian Fund must be realised before the Effective Date, and that the unit-holders' tax positions in relation to the units in the Norwegian Fund will be transferred and apportioned pro rata to the units in the Finnish Fund that are issued as merger consideration. The reali sation of equity posi- tions will be exempt from tax at the fund level under the Norwegian participation exemption.
4.3 Except for any tax consequences that may arise from the payment of a possible cash equalization amount (see further description in section 13.2.1 below), the merger will not have any tax consequences for the unit-holders. The merger will not be considered as a taxable realisation for Norwegian tax purposes for the unit-holders in the Norwegian Fund.
4.4 The unit-holders who exercise their right to redeem or exchange units without cost before the merger are for Nor- wegian tax purposes considered to have realised their units.