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Investor Presentaiton

Corporate tax aspects - Normal Dutch Company NEPI Rockcastle NV ('NRP NV') will be subject to 25.8% corporate income tax rate in the Netherlands ('NL') on a stand-alone basis Taxable profits in NL will include Group service fees and guarantee fees minus executive directors and staff remuneration costs minus operational costs The tax effect at the level of the Company would not materially impact distributable earnings, as most income is generated at the level of operational subsidiaries and taxed in their respective jurisdictions • Tax losses can be carried forward unlimitedly, but taxable profit in excess of €1 million can only be reduced by tax losses up to 50% NRP NV will benefit from double tax treaties (DTTS) concluded by the Netherlands as well as from EU Directives covering all countries where the Group is operating and the majority of its shareholders • A Dutch REIT regime is available in NL subject to certain criteria and applicable starting 1 January each year (based on option) RESPRESSO BOS etoj % BUN VENIT WHOPPE MON megamall 3 *** 12-b AX EFANEL
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