Investor Presentaiton

Illustrative TMK-TK Cashflow/Tax Leakage Diagram Indicative Effective Japanese Tax Rate Potentially around 13% to 20%. Payment of pre-tax dividends subject to 20.42% withholding tax. Potentially reducible under tax treaty, for example to 5% (Singapore) or 10% (PRC) or 15% (Australia). TMK level taxation should be minimal if managed correctly. Maximum around JPY2m per year. KPMG SPC 1 100% Dividends Investor 100% SPC 2 20.42% withholding on TK profit distributions. GK (TK Operator) TMK Ownership Dividends Real estate / Trust beneficial interest Prima facie 20.42% TK profit/ dividend withholding tax should apply. © 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. Equity holder Offshore Japan GK portion (typically 13%) taxed at standard corporate tax rate of approx. 35% Payment of pre-tax dividends subject to 20.42% withholding tax. This is fully creditable against tax liability of the branch (and refundable if in excess of tax liability). Pursuant to the 2022 Japan tax reforms, the WHT obligation on dividends payable on or after 1 October 2023 to domestic corporate shareholders that directly own more than one third of the total shares in a dividend paying entity is expected to be abolished. Document Classification: KPMG Confidential 19

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