Investor Presentaiton
High Level Comparison at a Glance
Form of investment interest
Ease and cost of set up
Timing for set up (lead time
for closing an investment)
TMK
Ownership of equity in property owning vehicle
Somewhat complicated, but widely used and
understood.
Around 2 months
TK
Contractual with more limited rights. This
means more limited legal control over the
asset.
Somewhat complicated, but widely used
and understood.
Around 2 months
Tax Robustness
Generally robust, subject to tax treaty eligibility
External Debt Financing
Required
Cash Repatriation
Somewhat cumbersome
Tax outcome dependent on
Yes
tax treaty benefit eligibility
Feasible for development
projects
Yes
Indicative Japanese
Effective Tax Rate
KPMG
Level of robustness will be very fact
specific. Often some level of potential
sensitivity
Optional. Lender friendly structure
Easy
(Generally) No
Yes
Approximately 20% - 27.5% dependent on tax
treaty (some potential further reduction through
internal financing, whilst a TMK-TK hybrid
approach could potentially reduce ETR to 12.5% -
20% or even lower if the investor into the TK is
Korean)
20.42%
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