Circular - Lippo Malls Indonesia Retail Trust - Investor Relations

APPENDIX CTAX CONSIDERATIONSThe following summary of certain Singapore income tax considerations to Unitholders in respectof the Proposed Acquisitions is based upon tax laws, regulations, rulings and decisions now ineffect, all of which are subject to change (possibly with retroactive effect). This summary is not atax advice and does not purport to be a comprehensive description of all the tax considerationsthat may be relevant to Unitholders. Unitholders should consult their own tax advisers on the taximplications that may apply to their own individual circumstances.SINGAPORE INCOME TAXIncome derived from the Proposed PropertiesThe rental income and other related income earned from the Proposed Properties will be receivedin Singapore by the relevant Singapore subsidiaries in a combination of some of the followingforms:(i)(ii)(iii)dividend income;interest income; andproceeds from repayment of shareholder’s loans.Any dividend income received in Singapore by the relevant Singapore subsidiaries from PPP andACU (the “Foreign Dividend Income”) will be exempt from tax under section 13(8) of the IncomeTax Act, Chapter 134 of Singapore (the “Income Tax Act”), provided that each of the relevantSingapore subsidiaries is a tax resident of Singapore and the following conditions are met:(i)(ii)(iii)in the year the Foreign Dividend Income is received in Singapore, the headline corporate taxrate of the jurisdiction from which it is received is at least 15.0%;the Foreign Dividend Income has been subjected to tax in the jurisdiction from which it isreceived; andthe Singapore Comptroller of Income Tax is satisfied that the tax exemption would bebeneficial to the relevant Singapore subsidiary.The relevant Singapore subsidiaries in respect of the Proposed Properties will make anapplication to the Inland Revenue Authority of Singapore to exempt the interest income receivedin Singapore from PPP and ACU from Singapore income tax under section 13(12) of the IncomeTax Act.This tax exemption, if granted to the relevant Singapore subsidiaries, will be subject to stipulatedconditions and will only apply to interest income received in Singapore on or before 31 March2015. Unless the tax exemption is subsequently extended by the Singapore Government, any ofsuch interest income received in Singapore after 31 March 2015 will be subject to Singaporeincome tax at the prevailing corporate rate of tax, currently 17.0%.Cash that cannot be repatriated by PPP and ACU in the form of dividends may be used by theseIndonesian subsidiaries to repay the principal amount of shareholder’s loans. The proceeds fromthe repayment of shareholder’s loans received in Singapore by the relevant Singaporesubsidiaries are capital receipts and hence not subject to Singapore income tax.C-1