Under current Bermuda law the Company and its subsidiary are not required to pay tax in Bermuda on either income or capital gains. The Company has received an undertaking from the Minister of Finance in Bermuda that in the event of such taxes being imposed, the Company is exempt from such taxation at least until 31 March 2035.

The Company may, however, be subject to foreign withholding taxes in respect of income derived from its investments in other jurisdictions. For the year ended 31 December 2023, the Company was not subjected to foreign withholding taxes (2022: nil).

During 2023, there were discussions between Oakley Capital Investments Limited (“OCI”) and its Bermudian tax advisers regarding the implementation of the Pillar 2 global minimum tax (GloBE) rules integrated into the Corporate Income Tax Act 2023 in Bermuda. The legislation introduces a 15% corporate income tax (“CIT”) that would apply to certain Bermuda Entities. Following the consultation, OCI is not expected to be within the scope of this 15% CIT.