(Constituted in the Republic of Singapore pursuant to a trust deed dated 31 March 2006 (as amended))

NOTICE OF RECORD DATE AND DISTRIBUTION PAYMENT DATE

NOTICE IS HEREBY GIVEN that the Transfer Books and Register of Unitholders of ESR-LOGOS REIT will be closed at 5.00 p.m. on 7 February 2023 for the purpose of determining Unitholders' entitlements to ESR- LOGOS REIT's distribution.

The Manager of ESR-LOGOS REIT has announced a distribution of 1.540 cents per ESR-LOGOS REIT unit for the period from 1 July 2022 to 31 December 2022 (the "Distribution") comprising the following components:

Taxable income distribution

1.287 cents per unit

Tax-exempt income distribution

0.085 cents per unit

Capital distribution

0.168 cents per unit

Unitholders whose securities accounts with The Central Depository (Pte) Limited are credited with ESR- LOGOS REIT units as at 5.00 p.m. on 7 February 2023 will be entitled to the Distribution that will be paid on or around 29 March 2023.

The Manager of ESR-LOGOS REIT hereby confirms that, after making payment of the Distribution, ESR- LOGOS REIT has sufficient financial resources to fulfil its liabilities as and when they fall due.

DECLARATION FOR SINGAPORE TAX PURPOSES

  1. Capital distribution

The capital component of the Distribution represents a return of capital to Unitholders for Singapore income tax purposes and is therefore not subject to income tax. For Unitholders holding ESR-LOGOS REIT units as trading assets, the amount of capital distribution will be applied to reduce the cost base of their ESR- LOGOS REIT units for the purpose of calculating the amount of taxable trading gains arising from the disposal of their ESR-LOGOS REIT units.

  1. Tax-exemptincome distribution

The tax-exempt income component of the Distribution is exempt from tax in the hands of all Unitholders, regardless of their nationality, corporate identity or tax residence status. No tax will be deducted at source for this component.

  1. Taxable income distribution

Tax will be deducted at source from the taxable income distribution in certain circumstances. The following section describes the circumstances in which tax will or will not be deducted from such distributions.

1. The Trustee and the Manager of ESR-LOGOS REIT will not deduct tax from distributions made out of ESR-LOGOS REIT's taxable income that is not taxed at the trustee level of ESR-LOGOS REIT to:

  1. Unitholders who are individuals and who hold the units either in their sole names or jointly with other individuals;
  2. Unitholders who are Central Provident Fund ("CPF") members who use their CPF funds under the CPF Investment Scheme and where the distributions received are returned to their CPF accounts;

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  1. Unitholders who are individuals and use their Supplementary Retirement Scheme ("SRS") funds and where the distributions received are returned to their SRS accounts;
  2. Unitholders which are companies incorporated and tax resident in Singapore;
  3. Unitholders which are Singapore branches of companies incorporated outside Singapore;
  4. Unitholders which are body of persons (excluding companies or partnerships) incorporated or registered in Singapore, such as:
    1. statutory boards;
    2. co-operativesocieties registered under the Co-operative Societies Act (Cap. 62);
    3. trade unions registered under the Trade Unions Act (Cap. 333);
    4. charities registered under the Charities Act (Cap. 37) or established by any written law; and
    5. town councils;
  5. Unitholders which are international organisations that are exempt from tax on such distributions by reason of an order made under the International Organisations (Immunities and Privileges) Act (Cap. 145); and
  6. Unitholders which are real estate investment trust exchange-traded funds which have been accorded the tax transparency treatment.

2. For distributions made to Unitholders who do not fall within the categories stated under Note 1 above, the Trustee and the Manager of ESR-LOGOS REIT will deduct tax at the rate of 10% if the Unitholders are:

  1. foreign non-individual investors - for distributions made during the period from 18 February 2005 to 31 December 2025; or
  2. foreign funds - for distributions made during the period from 1 July 2019 to 31 December 2025.

A foreign non-individual investor is one which is not a resident of Singapore* for income tax purposes and;

  1. which does not have a permanent establishment^ in Singapore; or
  2. which carries on any operation in Singapore through a permanent establishment in Singapore, where the funds used to acquire the units in ESR-LOGOS REIT are not obtained from that operation.

A foreign fund is one that qualifies for tax exemption under section 13CA, 13X or 13Y of the Income Tax Act that is not a resident of Singapore* for income tax purposes and;

  1. which does not have a permanent establishment^ in Singapore (other than a fund manager in Singapore); or
  2. which carries on any operation in Singapore through a permanent establishment in Singapore (other than a fund manager in Singapore), where the funds used to acquire the units in ESR- LOGOS REIT are not obtained from that operation.

3. Unitholders are required to complete the applicable Section A, B or C of the "Declaration for Singapore Tax Purposes Form A" ("Form A") if they fall within the categories (d) to (h) stated under Note 1, Section D of Form A if they qualify as a foreign non-individual investor as described under Note 2, or Section E of Form A if they qualify as a foreign fund as described under Note 2.

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  1. The Trustee and the Manager of ESR-LOGOS REIT will rely on the declarations made in Form A to determine (i) if tax is to be deducted for the categories of Unitholders listed in (d) to (h) under Note 1; and (ii) if tax is to be deducted at the rate of 10% for distributions to foreign non-individual investors and foreign funds as described under Note 2.
  2. Unitholders who fall within categories (a) to (c) under Note 1 are not required to submit Form A. The gross distribution received by these unitholders (irrespective of their tax residence status) is exempt from tax. However, this tax exemption does not apply to such unitholders in respect of distribution derived by them through a partnership in Singapore or from the carrying on of a trade, business or profession. Such unitholders, i.e., to whom the exemption does not apply, must declare the distribution received as income in their income tax returns.
  3. Unitholders who do not fall within the categories of Unitholders listed in Note 1 and Note 2 above can choose not to return Form A as tax will be deducted from the distributions made to them at the prevailing corporate tax rate in any case.
  4. The Trustee and the Manager of ESR-LOGOS REIT will deduct tax at the prevailing corporate tax rate from distributions made out of ESR-LOGOS REIT's taxable income that is not taxed at the trustee level of ESR-LOGOS REIT, in respect of units held by depository agents except where the beneficial owners of these units are:
    1. individuals and the units are not held through a partnership in Singapore;
    2. qualifying unitholders as listed in categories (d) to (h) under Note 1;
    3. foreign non-individual investors; or
    4. foreign funds.

For units held through the depository agents, the depository agents must complete the "Declaration by Depository Agents for Singapore Tax Purposes Form B" ("Form B") and its annexes.

  1. Form A and Form B (and its annexes) will be sent to Unitholders and depository agents respectively, by ESR-LOGOS REIT's Unit Registrar, Boardroom Corporate & Advisory Services Pte. Ltd., on or around 16 February 2023.
  2. Unitholders (Form A) and depository agents (Form B and its annexes) will have to complete the forms legibly and send it to the Unit Registrar such that it is received by 5.00 p.m. on 3 March 2023. The Trustee and the Manager of ESR-LOGOS REIT will rely on the declarations made in Form A and Form B to determine if tax is to be deducted. Failure to comply with any of these requirements will render Form A and Form B invalid and the Trustee and the Manager of ESR-LOGOS REIT will be obliged to deduct the appropriate amount of tax from the Distribution.
  3. Unitholders who hold units under the Central Provident Fund Investment Scheme ("CPFIS") and the Supplementary Retirement Scheme ("SRS") do not have to return the Form as they will receive gross distributions paid to their respective CPFIS and SRS accounts.

IMPORTANT REMINDER

Unitholders and depository agents must complete and return the "Declaration for Singapore Tax Purposes Form A and Form B (and its annexes)" to Boardroom Corporate & Advisory Services Pte. Ltd.'s office by 5.00 p.m. on 3 March 2023 in order to receive the Distribution either at gross or at net as described above.

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DECLARATION IN INCOME TAX RETURN

The Distribution is considered as income for the year 2022. Beneficial owners of the Distribution, other than those who are exempt from tax on the Distribution, are required to declare the taxable income component of the Distribution as taxable income in their income tax return for the Year of Assessment 2023.

IMPORTANT DATES AND TIMES

Timeline

31 January 2023 (Tue)

Event

Distribution Reinvestment Plan ("DRP") is only offered to Unitholders with registered addresses in Singapore. Those Unitholders who are resident outside Singapore must provide to The Central Depository (Pte) Limited addresses in Singapore for the service of notices and documents if they are interested in the DRP.

9.00 a.m., 6 February 2023 (Mon)

Units will be traded ex-distribution

5.00 p.m., 7 February 2023 (Tue)

Closure of ESR-LOGOS REIT's Transfer Books and

Register of Unitholders

16 February 2023 (Thu)

Despatch of Notice of Election and Tax Declaration

Form to Unitholders

5.00 p.m., 3 March 2023 (Fri)

Unitholders and depository agents must have

completed and returned the Notice of Election and Tax

Declaration Form to the Unit Registrar, Boardroom

Corporate & Advisory Services Pte. Ltd.

29 March 2023 (Wed)

Payment of distribution / Crediting and listing of the

DRP units

BY ORDER OF THE BOARD

ESR-LOGOS Funds Management (S) Limited

As Manager of ESR-LOGOS REIT

(Company Registration No. 200512804G, Capital Markets Services Licence No. 100132)

Adrian Chui

Chief Executive Officer and Executive Director

30 January 2023

For further enquiries, please contact:

ESR-LOGOS Funds Management (S) Limited

Lyn Ong

Sua Xiu Kai

Manager, Capital Markets and Investor Relations

Assistant Manager, Corporate Communications

Tel: +65 6222 3339

Tel: +65 6222 3339

Email: lyn.ong@esr-logosreit.com.sg

Email: xiukai.sua@esr-logosreit.com.sg

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Notes

  • A Company is not a resident of Singapore if the management and control of its business is exercised outside Singapore.
  • Under the Singapore Income Tax Act, permanent establishment means a fixed place where business is wholly or partly carried on including a place of management, a branch, an office, a factory, a warehouse, a workshop, a farm or plantation, a mine, oil well, quarry or other place of extraction of natural resources, a building or work site or a construction, installation or assembly project. A Unitholder shall be deemed to have a permanent establishment in Singapore if it:
    1. carries on supervisory activities in connection with a building or work site or a construction, installation or assembly project; or
    1. has another person acting on the Unitholder's behalf in Singapore who:
      1. has and habitually exercises an authority to conclude contracts;
      2. maintains stock of goods or merchandise for the purpose of delivery on its behalf; or
      3. habitually secures orders wholly and almost wholly for the Unitholder or for such other enterprises as are controlled by the Unitholder.

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ESR-REIT published this content on 08 February 2023 and is solely responsible for the information contained therein. Distributed by Public, unedited and unaltered, on 08 February 2023 10:03:08 UTC.