Scenario: Edward and Daniel Kelly, together with their friends Joseph Byrne and Steven Hart, have established the Avenal Estates SARL group of property companies. Each of the founders has a 15 per cent share of the holding company, the remaining shares being held by their principal backer, the Ruritania Teachers' Pension Fund. Edward and Daniel Kelly are Irish citizens domiciled in the UK and osenh Bvrne and Steven Hart are Australian. Avenal Estates SARI is domiciled in Luxembourg. Edward Kelly is its chief executive and chairman of the board of directors on which the four founders and a representative of the Ruritania Teachers' Pension Fund sit. There are no other directors The company has primarily been engaged in property development, in which it sold the properties developed on to other investors. It has recently changed direction with the purchase of two rundown shopping centres in small towns in the UK. The Maltings Shopping Centre in Causton is largely unoccupied, with there being no anchor tenant since the Tesco supermarket closed and just five of the 17 other units occupied by rent-paying tenants though several others have been let on license to community and charitable groups for nominal rents. The Orchard Centre in Kingsmarkham was anchored by a Debenhams store, which is now closed. It has 22 other units, 16 of which are currently occupied by rent-paying tenants, though four of these have secured Company Voluntary Arrangements, which have resulted in rent reductions and two national chains are currently withholding rent payments. It intends to retain the redeveloped centres as part of its portfolio and plans to buy more shopping centres in secondary British towns and cities The company currently has equity capital of 9 million and loan capital of 18 million, which includes a loan of 10 million from the Ruritania Teachers' Pension Fund due to be repaid in 2026 on a convertible basis into shares. The company plans to seek a listing on the UK Stock Exchange's Alternative Investment Market (AIM) and become a Real Estate Investment Trust (REIT) in the UK. Once it has obtained consent for an AIM listing, it plans an initial public offering of shares to raise 20 million in exchange for 30 per cent of the shares in the company. The company plans to change direction and develop a second strand to its portfolio. Having watched the growth in investment in logistics and warehouses in the UK, it feels that opportunities are now too highly priced to generate the returns it is seeking and Is lOoKing elsewhere. It has acquired options on sites on the Sava River in Belgrade for luxury residential developments. It is also considering investing in logistics and distribution centres in Serbia, encouraged by Chinese investment in the port of Piraeus and Serbian railways as part of its Belt and Road Initiative. It is considering financing these through loans borrowed in Swiss francs. Question: Discuss the opportunites and risks in investing in Its chosen sectors and countries. and the means it is proposing of raising capital. Assuming that the company secures REIT status in the UK, the tax implications for the company and its investors of its proposed strategy