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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% © 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 | 3
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