Investor Presentaiton

Some key merits and demerits of the TK Merits Debt funding and form of borrowing are optional. Further, where debt is obtained this is typically easier to arrange, less documentation intensive and more flexible. Relatively low, flat tax rate which may, depending on investor circumstances, provide a more favourable effective rate than under a TMK. Other than in the limited cases of exemption granting tax treaties, the Japanese tax result is not dependent on tax treaty eligibility. Can be more flexible for multiple property acquisitions. Faster turnaround of cash with administrative flexibility in distributing cash. No need to file amendments with financial regulators when plans change. Typically slightly lower establishment costs. Demerits TK investor cannot participate in the control or management of the TK business. If this is not respected, returns can become subject to full Japanese tax rates. Contractual interest only for investor; no equity or ownership of underlying assets. Potentially less certainty as to tax outcome relative to a TMK. Potentially cumbersome Financial Instruments and Exchange Law and/or Real Estate Syndication Law requirements. 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 |16

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