Page 9 - Listing a Real Estate Investment Trust in Singapore or China

PRC
Distributions receivable from S-REITs by PRC investors/unitholders will be liable to PRC income
tax at 25% (corporates) and 20% (individuals) respectively. This is no di erent, had it been
distributions receivable from C-REITs. The 10% Singapore withholding tax su ered on the
distributions from S-REITs should be creditable against the PRC tax payable by corporate
investors/unitholders on the same income upon the approval from the Chinese tax bureau.

APPENDIX

Singapore Section 13(12) tax exemption will be granted on S-REIT foreign income received by
the trustees of S-REITs or their wholly-owned Singapore resident subsidiary company if the
Comptroller of Income Tax (CIT) is satisfied that certain qualifying conditions are met. The table
below summarises the qualifying conditions:

FOREIGN-SOURCED DIVIDENDS / TRUST DISTRIBUTIONS BY FOREIGN-SOURCED
FOREIGN TRUSTS / FOREIGN BRANCH PROFITS INTEREST

(a) The income originates from an overseas entity with headline Same
tax rate of at least 15%

(b) Dividend/trust distribution/branch profits originate from Same
rental income from overseas property, capital gains from
disposal of such overseas property or income derived from
approved REIT property related activities

(c) Tax has been paid overseas on property rental income where Tax has been paid overseas on the
the overseas property is situated interest income. Where there is no
foreign tax paid, conditions apply

(d) Singapore source funds used to finance the overseas Same
property investment must originate from specified sources

(e) No setting up of artificial structures to avoid Singapore tax Same

(f) The remitted income less incidental expenses must pass Same
through to the S-REIT

(g) The Comptroller of Income Tax is satisfied that the above Same
conditions are met

For further information or assistance, please contact:

Koh Puay Hoon, Partner & Head of Tax Cindy Lim, Partner
T +65 6594 7820 T +65 6594 7852
KohPuayHoon@RSMSingapore.sg CindyLimLH@RSMSingapore.sg

William Chua, Partner Loke Yew Ken, Tax Director
T +65 6594 7860 T +65 6594 7861
WilliamChuaKH@RSMSingapore.sg LokeYewKen@RSMSingapore.sg

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