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

Units, whichever is the lesser) at any time convene a meeting ofUnitholders in accordance with the provisions of the Trust Deed.No Redemption by Unitholders . . . . .Distribution Policy . . . . . . . . . . . . . . .Singapore Tax Considerations . . . . . .Unitholders have no right to request the Manager to redeemtheir Units while the Units are listed. It is intended thatUnitholders may only deal in their listed Units throughtrading on the SGX-ST. Listing of the Units on the SGX-ST does not guarantee a liquid market for the Units.LMIR Trust’s distribution policy is to distribute 100.0% of its taxexemptincome (after deduction of applicable expenses) andcapital receipts for Forecast Period 2007, Projection Year 2008and Projection Year 2009 and at least 90.0% of its tax-exemptincome (after deduction of applicable expenses) and capitalreceipts thereafter. Distributions will be paid on a quarterlybasis to Unitholders, except for the first distribution, which willbe paid for the period from the Listing Date to 31 March 2008 andwill be paid by the Manager on or before 30 May 2008 (see“Distributions”).Unitholders will be exempt from Singapore income tax ondistributions made by LMIR Trust out of its tax-exempt income.Unitholders will not be subject to Singapore income tax ondistributions made by LMIR Trust out of its capital receipts,comprising amounts received from redemption of redeemablepreference shares in the Target Singapore SPCs. Thesedistributions will be treated as returns of capital for Singaporeincome tax purposes. For Unitholders who hold the Units astrading or business assets and are liable to Singapore incometax on gains arising from disposal of the Units, the amount ofsuch distributions will be applied to reduce the cost of the Unitsfor the purpose of calculating the amount of taxable trading gainwhen the Units are disposed of. If the amount distributedexceeds the cost or the reduced cost of the Units, as thecase may be, the excess will be subject to tax as tradingincome of such Unitholders (see “Taxation”).Indonesia Tax Considerations . . . . . .The income received by the Indonesian SPCs solely from rentalpayments by the Master Lessee and the tenants is subject tofinal income tax in Indonesia at the rate of 10.0%.The Indonesian SPCs charge value-added tax (“VAT”) at therate of 10.0% on the rental income from the Master Lessee andthe tenants.The income received by LMIR Trust through the TargetSingapore SPCs in the form of dividends and interestpayments is subject to tax in Indonesia at the rate of 10.0%based on the provisions of the Singapore-Indonesia tax treaty.The withholding tax on the dividends and interest payments ispayable when it is accrued or paid, whichever comes first.Termination of LMIR Trust . . . . . . . . .LMIR Trust can be terminated if the Unitholders’ approval isobtained by passing a resolution proposed and approved by amajority consisting of 75.0% or more of the total number of votescast for and against such resolution (an “ExtraordinaryResolution”) at a Unitholders’ meeting duly convened andheld in accordance with the provisions of the Trust Deed. Asspecified in the Trust Deed, the Manager or the Trustee mayterminate LMIR Trust under certain circumstances such asLMIR Trust being delisted permanently from the SGX-ST (see58