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Illustrative TK Cashflow/Tax Leakage Diagram Effective Japanese Tax Rate 20.42%* The TK Operator will typically need to receive some return. Hence, the GK and/or domestic investor will ordinarily have some taxable income also. The specifics of this will depend on individual circumstances. Offshore Co (TK Investor) TK Profit Distributions Domestic investor Non- managing member GK (TK Operator) Ownership Managing member Real estate / Trust beneficial interest 20.42% withholding on profit distributions. For profit distributions to a genuine Korean resident investor potentially 0%. Ippan Shadan Hojin 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. Offshore Japan * This rate can be reduced to 0% by certain tax treaties that give taxing rights to the other country. The Japan - Korea tax treaty is one such example. Any such arrangements would be considered aggressive by the tax authorities and as such would require careful consideration. Document Classification: KPMG Confidential 14

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