Page 5 - Listing a Real Estate Investment Trust in Singapore or China
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Taxation of REITS in Singapore
        Illustration of a REIT listed  in Singapore  solely  holding properties in the People's  Republic  of
        China (“PRC”)






                                       Investors                 Investors               Tax treatment on
                                                                                         REIT distribution
                                     (unitholders)
                                                                 Individuals (resident   Exempt
                                                                 & non-resident)

                  > 90% distribution                             Singapore resident      Taxed on
                  (tax transparency                              companies               non-exempt portion
                        rules apply)
                                                                 Non-Singapore           10% final
                                                                 resident corporates     withholding tax

                                S-REIT





                                                  Sec 36 of the Stamp Act
                                                  Stamp duty exemption for any instrument for the
                                                  sale, transfer, lease or other disposition, either
                                                  absolutely or by way of mortgage or otherwise, of
                                                  land situated outside Singapore or any share, estate
                Singapore                         or interest in land situated outside Singapore.

                    PRC
                                                  Sec 13(8) Exemption




                                        ·  Dividends
                                        ·  Loan interest           Sec 13(12) exemption
                                        ·  Property management
                                         income



                                                                         China investors in      Tax on REIT
                                                                         S-REIT                  distribution

                                     PRC company                         Resident individuals       20%
                                  holding properties
                                                                         Resident corporations      25%














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