LIPPO-MAPLETREE - Lippo Malls Indonesia Retail Trust - Investor ...

Appendix CINDEPENDENT SINGAPORE TAXATION REPORTThe Board of DirectorsLippo-Mapletree Indonesia Retail Trust Management Ltd.as Manager of Lippo-Mapletree Indonesia Retail Trust78 Shenton Way#05-01 Lippo CentreSingapore 079120HSBC Institutional Trust Services (Singapore) Limitedas Trustee of Lippo-Mapletree Indonesia Retail Trust21 Collyer Quay#14-01 HSBC BuildingSingapore 04932019 October 2007Dear SirsSINGAPORE TAXATION REPORTThis letter has been prepared at the request of Lippo-Mapletree Indonesia Retail Trust Management Ltd.(the “Manager”) for inclusion in the Prospectus for Lippo-Mapletree Indonesia Retail Trust (“LMIR Trust”)dated 19 October 2007 in connection with the listing of LMIR Trust on the Singapore Exchange SecuritiesTrading Limited.The purpose of this letter is to provide prospective purchasers of the units in LMIR Trust (“Units”) with anoverview of the Singapore income tax consequences of the purchase, ownership and disposition of theUnits. This letter principally addresses Unitholders who hold the Units as investment assets. Unitholderswho hold or have acquired the Units for dealing purposes should consult their own tax advisers concerningthe tax consequences of their particular situations.This letter is not a tax advice and does not attempt to describe comprehensively all of the taxconsiderations that may be relevant to a decision to purchase, own or dispose of the Units.Unitholders should consult their own tax advisers concerning the tax consequences of their particularsituations. In particular, Unitholders who are not Singapore tax residents are advised to consult their owntax advisers to take into account the tax laws of their respective countries of residence and the existence ofany tax treaty which their countries of residence may have with Singapore.This letter is based on the Singapore income tax law and the relevant interpretation thereof current at thedate of this letter, all of which are subject to change, possibly with retroactive effect.Words and expressions in this letter have the same meaning as defined in the Prospectus. In addition,unless the context requires otherwise, words in the singular include the plural and the other way aroundand words of one gender include any gender.SINGAPORE TAXATION OF REAL ESTATE INVESTMENT TRUSTS IN GENERALUnder current Singapore income tax law, the taxable income of a trust comprises:(a)(b)income accruing in or derived from Singapore; andunless otherwise exempt, income derived from outside Singapore which is received in Singapore ordeemed to have been received in Singapore by the operation of law.The taxable income of a trust is ascertained in accordance with the provisions of the Singapore income taxlaw, after deduction of all allowable expenses and any other allowances permitted under the law.C-1