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Key Differences: Business Trusts, REITs and Listed Companies in Singapore Regulatory Regime Constitution Responsible Entity Board of Directors Asset Depreciation/ Revaluation Gearing Limit Taxation on Distributions Source: Adapted from SGX-ST website . • . . Business Trust Business Trusts Act Not a separate legal entity Created by a trust deed Unitholders have beneficial interest and a lesser degree of control than shareholders of a company Trustee-Manager as the single responsible entity with its role similar to the combined roles of the REIT's asset manager and trustee Majority of directors must be independent Higher standard of independence . • • No restriction No impact on distribution payout • None • Distributions are net of tax S-REIT Code on Collective Investment Scheme Not a separate legal entity Created by a trust deed Unitholders have beneficial interest and a lesser degree of control than shareholders of a company Trustee and Asset Manager are separate entities One-third of the Board to consist of independent directors . Real estate • No impact on distribution payout 45% of deposited property Tax transparent if more than 90% of taxable profits are distributed Listed Company Companies Act . A separate legal entity Board of directors and management At least two nonexecutive directors who are independent and free of any material business or financial connection with the company No restriction Affects dividend payout, which is restricted to accounting profits None Dividends are net of tax Keppel Infrastructure Trust 14

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