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Investor Presentaiton

Introduction The Japanese corporate tax rate (effective rate approximately 31-35%) is one of the highest in the developed world. This makes tax a very important consideration in undertaking Japanese real estate investments. Inward investment in Japanese real estate by large investors is predominantly conducted using one of two structures (or a combination of these) which each offer favourable tax treatment: - A Tokumei Mokuteki Kaisha (TMK) based structure; or - A Tokumei Kumiai (TK) based structure. • . This slide pack provides an overview of some of the key tax and related considerations associated with these structuring approaches. The information in this slide pack is for general information purposes only and does not represent a comprehensive or exhaustive analysis of the relevant Japanese tax treatments applicable to the indicated investment structures, nor to all potential variations on these structures. It is imperative that specific advice be sought on the tax position for particular investment transactions and structures. 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 2
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