In a press release of 15 September 2006, the Luxembourg tax authorities announced that the Luxembourg and Israeli tax authorities had agreed that Luxembourg investment funds (SICAVs and SICAFs) and Israeli collective investment vehicles fall within the scope of the Luxembourg-Israel income and capital tax treaty of 13 December 2004. Consequently, both tax authorities will from 15 September 2006 issue a certificate of residence in respect of the vehicles concerned. The announcement emphasizes that the proposed changes do not amount to a capital gains tax. Accordingly, if the actual return exceeds 5%, there will be no amount to carry forward....