Spark Infrastructure : 2017 Tax Guide

Wednesday, 16 August 2017

The Manager

Company Announcements Australian Stock Exchange Limited 20 Bridge Street

SYDNEY NSW 2000

Dear Sir / Madam

2017 Tax Guide

Please find attached Spark Infrastructure's 2017 Tax Guide which is applicable to the financial year ended 30 June 2017.

Yours faithfully,

Alexandra Finley Company Secretary

Spark Infrastructure RE Limited ABN 36 114 940 984

as Responsible Entity of Spark Infrastructure Trust (ARSN 116 670 725) Level 25, 259 George Street Sydney NSW 2000 Australia

T [phone] F [phone]

www.sparkinfrastructure.com

2017 TAX GUIDE Essential information to help you complete your 2017 Australian income tax return

IMPORTANT INFORMATION

This Tax Guide has been prepared in good faith based on information believed to be accurate at the date of issue, but to the maximum extent permitted by law, no warranty of accuracy or reliability is given and no responsibility arising in any other way including by reason of negligence for errors or omissions

in this Tax Guide is accepted by Spark Infrastructure RE Limited ABN 36 114 940 984 as responsible entity of Spark Infrastructure Trust ARSN 116 870 725 or any other member of the Spark Infrastructure Group. This Tax Guide is not financial product advice and does not constitute tax advice.

Securityholders should obtain their own professional advice, as necessary, in connection with the completion of their tax returns and to meet their own financial situation and needs.

AFSL 290436

AUGUST 2017

DEAR SECURITYHOLDER,

This Tax Guide should be read in conjunction with your Spark Infrastructure Distribution Statements. These documents contain information that will help you complete your 2017 Australian income tax return.

Spark Infrastructure is a single listed entity through Spark Infrastructure Trust (Spark Trust). Securities in Spark Infrastructure comprise a Loan Note and a unit issued by Spark Trust (Spark Infrastructure securities). The Loan Note and units in Spark Trust are stapled, meaning they cannot be traded separately. The current structure is shown

in the diagram below.

If you are NOT an individual but you were a resident of Australia for income tax purposes at all times during the year

ended 30 June 2017, you will need to reflect distributions from Spark Trust appropriately in your 2017 Australian income tax return and reflect any gain or loss on disposal

of any or all of your Spark Infrastructure securities during the year ended 30 June 2017 in your 2017 Australian income tax return.

The information contained in this Tax Guide, together with your Spark Infrastructure Distribution Statements, may assist you with the information you need to complete your 2017 Australian income tax return.

SECURITYHOLDERS

Stapled security consists of a Loan Note and a Spark Trust Unit

SPARK INFRASTRUCTURE TRUST
SPARK INFRASTRUCTURE ELECTRICITY ASSETS TRUST	SPARK HOLDINGS 3	SPARK HOLDINGS 2	SPARK HOLDINGS 1
15.01%		15.01%		49%		49%
NSW ELECTRICITY NETWORKS ASSETS HOLDINGS TRUST*	NSW ELECTRICITY NETWORKS OPERATIONS HOLDINGS TRUST*	SA POWER NETWORKS PARTNERSHIP	VICTORIA POWER NETWORKS PTY LTD

If you were NOT a resident of Australia for all or part of the year ended 30 June 2017, you will need to decide whether to lodge a 2017 Australian income tax return. If you do lodge a return, the information contained in the Spark Infrastructure Distribution Statements you received in respect of each distribution and this Tax Guide may assist you.

The attribution managed investment trust regime (known as the AMIT regime) came into effect from 1 July 2016. The implications of the new AMIT regime on Spark Trust and whether to elect to adopt the new regime and from what date, is currently being determined by the trustee of Spark Trust.

*Together referred to as TransGrid

1. Please note that any gain or loss made on the Loan Notes will always be on revenue account (refer page 6)

2. The 2010 Restructure relates to the Spark Trust becoming the parent entity of the Spark Infrastructure group, with Spark Infrastructure Holdings No. 1 Pty Limited (Spark Holdings 1), Spark Infrastructure Holdings No. 2 Pty Limited

(Spark Holdings 2) and Spark Infrastructure Holdings No. 3 Pty Limited (Spark Holdings 3) as its subsidiaries at that point in time.

This Tax Guide has been prepared specifically for individuals who were tax residents

of Australia throughout the year ended 30 June 2017 and who held their Spark

Infrastructure securities on capital account1.

Part A will assist you in reporting your Spark Infrastructure distributions in your 2017 Australian income tax return.

If you disposed of any or all of your Spark Infrastructure securities during the year ended 30 June 2017 (or entered into a contract on or before 30 June 2017 to do so), you will need to consider the income tax (including capital gains tax (CGT)) consequences of that disposal. Part C of this Tax Guide contains information that may assist you in this regard.

Please note that if you held any Spark Infrastructure securities on or before

20 December 2010 (the 2010 Restructure2), you will need to consider the impact of the 2010 Restructure on the tax cost base and

acquisition date of those units held in the Spark Trust at that time. This will be relevant for the calculation of your gain or loss on disposal of those Spark Infrastructure securities during the year ended 30 June 2017. Part B of this

Tax Guide contains information that may assist you in this regard.

If you require further factual information, please contact Investor Relations on [phone].

You should consult your tax adviser if you require tax advice on any of the issues in this Tax Guide, or in relation to the completion of your 2017 Australian income tax return.

Yours sincerely

RICK FRANCIS

MANAGING DIRECTOR

2 | SPARK INFRASTRUCTURE

INDIVIDUALS - HOW TO COMPLETE YOUR 2017 AUSTRALIAN INCOME TAX RETURN

PART A: SPARK INFRASTRUCTURE DISTRIBUTIONS

In respect of the year ended 30 June 2017, Spark Trust paid the following distributions:

• 15 September 2016: 7.25 cents per Spark Infrastructure security consisting of 3.50 cents of interest on the Loan Notes and 3.75 cents of tax deferred distributions; and

• 15 March 2017: 7.25 cents per Spark Infrastructure security consisting of 3.55 cents of interest on the Loan Notes and

3.70 cents of tax deferred distributions.

Interest Income

You should include the total interest you received at item 10L of your 2017 Australian income tax return.

If there is an amount on your Spark Infrastructure Distribution Statements for "Tax File Number (TFN) withholding", it represents TFN withholding tax deducted from your Spark Infrastructure distributions because you did not supply your TFN or (where relevant) an Australian Business Number (ABN) and you did not claim an exemption for your Spark

Infrastructure investment. If the amount of tax withheld has not previously been refunded to you, you may claim a credit for it by including the amount of TFN withholding tax deducted at item 10M of your 2017 Australian income tax return.

The pictorial overview below shows the relevant part of the 2017 Australian income tax return to include the total interest received and (where relevant) the amounts of TFN withholding not previously refunded to you.

Tax deferred distributions

Assuming you held your Spark Infrastructure investment on capital account for income tax purposes (i.e. not as trading stock or otherwise on revenue account), the tax deferred components of your Spark Infrastructure distributions on your Spark Infrastructure Distribution Statements should not form part of your assessable income for tax purposes and do not have to be reported in your 2017 Australian income tax return, except possibly as described below.

The tax deferred components of your Spark Infrastructure distributions received during the year ended 30 June 2017 will reduce the cost base (or reduced cost base) of your units in Spark Trust for CGT purposes. To the extent that a tax deferred amount exceeds your cost base in the units of Spark Trust, then you will make an immediate capital gain equal to the excess.

While many Securityholders hold their investment in Spark Trust on capital account, in certain circumstances, the investment may have been held on revenue account. Where your investment is held on revenue account, the tax deferred components of your Spark Infrastructure distributions may be treated as assessable income for tax purposes. If you believe that you held your Spark Infrastructure investment on revenue account, or if you are in any doubt, you should seek advice and consult your tax adviser.

10 Gross interest

Income - do not show cents

If you are a foreign-resident make sure you have printed your country of residence on page 1.

M $ ,

Tax file number amounts .

withheld from gross interest

Gross interest L $ ,

, .00

TAX GUIDE 2017 | 3