(i) (ii) (iii) (iv) (v)

Singapore, Malaysia, Hong Kong, Thailand & S Korea.

Listing HK Mandatory to list on Hong Kong Stock Exchange SG REIT must be listed on the Singapore Exchange to be eligible for tax concessions In order to be able to list must have S$20 mln. of assets Korea Self-Management REIT and Entrusted Management REIT mandatory listing on the Korea Stock Exchange (or trading in the association brokerage market of the Korea Securities Dealers Association) CR-REIT optional Malaysia Thailand Assets Thailand Investment can be made in real property that can generate rental revenue, except for those listed on the negative list, as follows: 1. real property involving illegal businesses; 2. real property that may have an environmental impact exceeding the legal limitation; 3. real property involving an "immoral business," such as massage parlors, night clubs, horse racing tracks, etc.; and 4. others, as specified by the SEC. 5. Investment can only be made in real property that is 80%-100% complete. 6. Only real property representing not more than 10% of NAV can be developed. 7. Investment shall not be made in vacant land, except:
investment for real property development according to the above; or if it can be demonstrated that it supports the income of the REIT's property

Korea Self-Management REIT: at least 70% of assets must be invested in real estate assets, at least 10% in real estate associated securities CR-REIT: at least 70% of the asset must be invested in real estate placed in the market as a result of corporate restructuring Entrusted Management REIT: at least 70% of assets must be invested in real estate assets, at least 10% in real estate associated securities SG Investments are restricted to the following permissible investments: eal estate-related assets

property company

Within the investment universe, the following restrictions apply: -producing real estate ventures or by investing in unlisted property development companies, unless the REIT intends to hold the developed property upon completion -backed securities) property developments (local and foreign) should not exceed 10% of its total assets or foreign non-property companies, government securities and securities issued by supranational agencies or a Singapore statutory board, and cash and equivalent items, not more than 5% of the REITs deposited property can be invested in any one issuers securities or any one managers funds, but note this does not apply to deposits placed with eligible financial institutions and investments in high-quality money market instruments or debt securities rental payments to be made by tenants and interest, dividends and other similar payments from investments held by the REIT REITs deposited property, except if a credit rating of the fund has been obtained and disclosed to the public, in which case the aggregate leverage can be up to 60% of the deposited property At least 70% of the funds deposited property should be invested in real estate and real estate related assets May also invest in immovable property related assets such as listed or unlisted debt securities, listed shares of property companies, mortgage-backed securities, other property funds, and assets incidental to the ownership of immovable property, listed shares of non-property corporations and government securities Cannot undertake development activities, whether directly, through joint ventures or indirectly including investment in unlisted property development companies. Not allowed to invest in vacant land and mortgages In principle, can invest in overseas real estate, however, Tax Ruling is premised on SREITs only investing in Singapore real estate HK Can invest in real estate anywhere in the world Investing in hotels and recreation parks is permitted Cannot invest in vacant land or participate in property development activities Real estate must generally be income generating, exceptions allowed for buildings in the course of substantial redevelopment or refurbishment Some restrictions when investing through SPVs Malaysia A real estate investment trust may only invest in the following:

(a) Real estates; (b) Single-purpose companies; (c) Real estate-related assets; (d) Non-real estate-related assets; and (e) Cash, deposits, and money market instruments. At least 50% of a funds total asset value must be invested in real estate and/or single-purpose companies at all times. A funds investment in non-real estate-related assets and/or cash, deposits and money market instruments must not exceed 25% of a funds total asset value.

Gearing Singapore According to the MAS Code on Collective Investment Schemes, there is actually a gearing limit for the REITs. Following is the extract of the related section Aggregate Leverage Limit, under section 9.2: 35% of its deposited property May exceed 35% of its deposited property (up to a maximum of 60%) if the REIT has obtained a credit rating from either Fitch Inc, Moodys or Standard and Poors, which is then disclosed to the public. The REIT must then continue to disclose its credit rating until its borrowings drop to 35% (or below) of its deposited property Total borrowings should not exceed 35% of the total asset value of the fund. The gearing limit may increase to a maximum of 60% if a credit rating from Fitch Inc, Moodys or Standard and Poors is obtained. Malaysia Total borrowings should not exceed 50% of the total asset value of the fund. Source: SC Guidelines for REITs and MAS Code on Collective Investment Schemes Thailand Under the Thai regulations, a REIT can have a maximum gearing of 35% of total asset value and the ceiling could be lifted to 60% if a particular REIT earns an investment-grade rating. Not more than 35% of NAV for investment or improvement of the invested property (2010) Source: bakermckenzie. Hong Kong The maximum borrowing limit for a Hong Kong retail REIT is increased from 35% of gross asset value to 45%. Borrowings shall not exceed 45% of the total gross asset value South Korea Ten times REITs net worth, albeit subject to a special resolution of the REITs general meeting of Shareholders Taxation SG Listed property trusts are taxable and unit holders tax exempt

Tax ruling: trust is transparent and unit holders are taxed at prevailing income tax rate on distribution Foreign corporate taxed at concessionary 10% income tax rate with effect from 18 Feb 2005 Foreign individuals not taxed Local parties taxed at normal income tax rate of 20% (but they can deduct related expenditure to generate the income) MY Income tax rate 27% The trust itself is taxable/unit holders tax exempt Trust is tax transparent if listed on the Malaysian stock exchange and meets the Securities Commission guidelines (M--REITS) M--REITS are tax exempt on net income provided 90% of total income is distributed to investors (tax credit for investors if 90% not met) Distributions made by listed REITS are subject to 15% final income tax for 5 yrs as of 1 January 2007 unless unit holder is FII FIIs are subject to 20% for 5 yrs as of 1 January 2007 Transfer of property is subject to stamp duty at rates ranging from 1--3% depending on the size of the transaction Exemption of stamp duty for transfer of property to M--REIT HK Income tax rate 17.5% The trust itself is taxable/unit holders tax exempt Transfer of property is subject to stamp duty at rates ranging from 0.75--3.75% depending on the size of the transaction REIT subject to 16% Hong Kong Property Tax on 80% of rental income after deducting bad rental receivables Dividends from SPVs held by REIT are tax exempt SPVs are taxed normally No stamp duty exemptions Investors are not subject to HK Profits Tax on distributions Non--listed REITS would be taxed as normal trusts: trust is subject to Profits Tax on its income and investors are tax exempt

Korea Subject to corporate income tax (12.1%, including resident surtax, for taxable income up to KRW 200 mln. and 24.2% above), but distributions are deductible if 90% or more of the distributable proits are declared or distributed as dividend in only CR-REIT, Entrusted Management REIT

Subject to corporate income tax (12.1%, including resident surtax, for taxable income up to KRW 200 mln. and 24.2% above), but distributions are deductible if 90% or more of the distributable proits are declared or distributed as dividend in only CR-REIT, Entrusted Management REIT Additionally, the sale of certain tainted assets such as housing or non-business land is subject to capital gains surtax at a rate of 33%, including resident surtax. 15.4% tax for distributions to resident individuals No withholding tax for distributions to resident corporations 22% for distributions to non-residents which may be reduced under the applicable tax treaty. Thailand A transfer of assets between the trustor (or settlor) and the trustee is exempt from income tax, value-added tax (VAT), specific business tax and stamp duty; b) Income from the operation of the trust asset (except for the trust management fee) is exempt from income tax; and c) Any distribution paid out of profits deriving from dividends (so-called "manufactured dividends") is entitled to 10% final withholding tax. Source: Royal Decree No.533

mb+1 hs 3 bp 3 hc 2 brh1