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Investor Presentaiton

Some key merits and demerits of the TMK Merits No requirement for passive investment, so investors can maintain control and ultimate ownership. Competitive tax rate where a beneficial tax treaty dividend withholding tax rate can be accessed. Potential for greatest certainty on tax treatment. Potential reduction in property acquisition taxes, which is especially beneficial where target real estate is unentrusted. Demerits Sources of funding are restricted by the TMK related laws (practically, bonds will have to be issued to Tax QII) with attendant additional costs and administration associated with the preparation of the relevant documentation etc. Less flexibility regarding repatriation of cash. Pre-liquidation this requires a dividend or a redemption of preferred equity. Relatively burdensome regulatory requirements on set up and maintenance. Typically higher set up and running costs as more entities are required. Tax rate achievable very dependent on availability of tax treaty benefits. Access to and robustness of tax treaty positions may be more challenging under the BEPS / Multilateral Instrument regime, particularly for collective investment arrangements. KPMG © 2023 KPMG Tax Corporation, a tax corporation incorporated under the Japanese CPTA Law and a member firm of the KPMG global organization of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved. Document Classification: KPMG Confidential 8
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