(a real estate investment trust constituted on 10 October 2013 under the laws of the Republic of Singapore)

NOTICE OF BOOKS CLOSURE AND DISTRIBUTION PAYMENT DATE

NOTICE IS HEREBY GIVEN that the Transfer Books and Register of Unitholders and the Transfer Books and Register of CPPU Holder of OUE Commercial Real Estate Investment Trust ("OUE C-REIT") will be closed at 5.00 p.m. on Friday, 6 August 2021 (the "Books Closure Date") for the purpose of determining:-

  1. the entitlement of holders of units in OUE C-REIT ("Units" and holders of Units, "Unitholders") to OUE C-REIT's distribution of 1.23 cents per Unit for the period from 1 January 2021 to 30 June 2021 (the "Distribution"), comprising
    1. a taxable income distribution of 0.87 cents per Unit,
    2. a tax exempt income distribution of 0.29 cents per Unit, and
    3. a capital distribution of 0.07 cents per Unit; and
  2. the entitlement of holder of convertible perpetual preferred units in OUE C-REIT ("CPPUs" and holder of CPPUs, "CPPU Holder")1 to OUE C-REIT's distribution of S$1,090,958.902 for the period from 1 January 2021 to 30 June 2021 (the "CPPU Distribution").

Unitholders whose securities accounts with The Central Depository (Pte) Limited are credited with Units as at the Books Closure Date will be entitled to the Distribution that will be paid on Friday, 10

September 2021.

CPPU Holder whose accounts with OUE C-REIT's Unit Registrar, Boardroom Corporate & Advisory Services Pte. Ltd. (the "Unit Registrar"), are credited with CPPUs as at 5.00 p.m. on the Books Closure Date will be entitled to the CPPU Distribution that will be paid on Friday, 10 September 2021.

  1. The CPPUs were issued to Clifford Development Pte. Ltd. (a subsidiary of OUE Limited), as part payment of the purchase consideration to OUE Limited for OUE C-REIT's acquisition of an 83.33% indirect interest in One Raffles Place. There is only one CPPU Holder as at the date of this announcement. The CPPU Holder is entitled to a distribution of an amount equivalent to 1.0% per annum of the issue price of S$1.00 per CPPU.
  2. The CPPU Distribution excludes the special preferred distributions paid to the CPPU Holder on 1 June 2021 pursuant to redemption of the CPPUs made on this date. Please refer to OUE C-REIT's announcement on 1 June 2021 for more details.

DECLARATION FOR SINGAPORE TAX PURPOSES

  1. The ordinary Distribution ("Distributions") will comprise three types of distribution - distribution of taxable income ("Taxable Income Distribution"), distribution of tax exempt income ("Tax Exempt Income Distribution") and distribution of capital ("Capital Distribution").
  2. The Tax Exempt Income Distribution is exempt from tax in the hands of all Unitholders/CPPU Holder. No tax will be deducted at source from this component.
  3. The Capital Distribution is treated as a return of capital to Unitholders/CPPU Holder for Singapore income tax purpose and is therefore not subject to Singapore income tax. For Unitholders/CPPU Holder who are liable to Singapore income tax on profits from sale of Units/CPPUs, the amount of Capital Distribution will be applied to reduce the cost base of their Units/CPPUs for Singapore income tax purposes.
  4. 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 distribution.
  5. The following categories of Unitholders/CPPU Holder will receive a gross distribution (i.e. no tax will be deducted from it):-
    1. holders who are individuals and who hold the Units/CPPUs either in their sole names or jointly with other individuals;
    2. holders which are companies incorporated and tax resident in Singapore;
    3. holders which are Singapore branches of foreign companies;
    4. holders which are non-corporate entities (excluding partnerships) constituted or registered in Singapore;
    5. holders 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. holders which are real estate investment trust exchange-traded funds which have been accorded the tax transparency treatment.
  6. To receive a gross distribution, Unitholders/CPPU Holder in categories (b) to (f) under Paragraph 5 above must complete a prescribed form - the "Declaration for Singapore Tax Purposes Form" ("Form A").
  7. These categories of Unitholders/CPPU Holder, unless they are exempt from tax because of their own circumstances, will have to pay income tax subsequently at their own applicable tax rates.
  1. Unitholders/CPPU Holder in category (a) under Paragraph 5 above are not required to submit any form. The gross distribution received by these Unitholders/CPPU Holder (irrespective of their tax residence status) is exempt from tax if it is not derived through a partnership in Singapore or from the carrying on of a trade, business or profession, such Unitholders/CPPU Holder must declare the distributions received as income in their Singapore income tax returns.
  2. Tax at the reduced rate of 10% will be deducted from the distribution made to foreign non- individual Unitholders/CPPU Holder or foreign funds.
    A foreign non-individual Unitholder/CPPU Holder is one (other than an individual) who is not a resident of Singapore for income tax purposes and:-
    1. who does not have a permanent establishment in Singapore; or
    2. who carries on any operation in Singapore through a permanent establishment in Singapore, where the funds used to acquire Units/CPPUs in OUE C-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. who does not have a permanent establishment in Singapore (other than a fund manager in Singapore); or
  2. who 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 Units/CPPUs in OUE C-REIT are not obtained from that operation.

A foreign fund refers to a fund being a non-resident company, a partnership where all partners are non-residents, a trust administered by a non-resident trustee, or a non-resident entity.

  1. To receive the gross distribution net of tax deducted at 10%, foreign non-individual Unitholders/CPPU Holder or foreign funds are required to complete Form A.
  2. Beneficial owners of Units/CPPUs in OUE C-REIT who hold their Units/CPPUs through depository agents will receive:-
    1. gross distribution if they are persons described in categories (a) to (f) under Paragraph 5 above; and
    2. distribution net of tax deducted at 10% if they are foreign non-individuals or foreign funds described in Paragraph 9 above.
  3. To receive gross distribution and distribution net of tax deducted at 10%, depository agents are required to complete the "Declaration by Depository Agents for Singapore Tax Purposes Form" ("Form B") and its annexes.
  1. Form A and Form B (and its annexes) will be sent to Unitholders/CPPU Holder and depository agents respectively, by the Unit Registrar on or around 11 August 2021.
  2. Unitholders/CPPU Holder (Form A) and the depository agents (Form B and its annexes) will have to complete the forms legibly and send it to the Unit Registrar such that they are received by the Unit Registrar by 5.00 p.m. on Friday, 20 August 2021. DBS Trustee Limited, as trustee of OUE C-REIT (the "Trustee"), and OUE Commercial REIT Management Pte. Ltd., as manager of OUE C-REIT (the "Manager"), 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 Manager of OUE C-REIT will be obliged to deduct the appropriate amount of tax from the Distributions in respect of which this announcement is made.
  3. Unitholders and CPPU Holder who hold Units/CPPUs 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 as long as the Distributions is paid to their respective CPFIS and SRS accounts.

DECLARATION IN INCOME TAX RETURN

The Distributions are considered as income for the year 2021. Beneficial owners of the Distributions, other than those who are exempt from tax on the Distributions or who are entitled to the reduced tax rate of 10%, are required to declare the gross amount of the Distributions as taxable income in their Singapore income tax return for the year of assessment 2022.

IMPORTANT REMINDER

Unitholders/CPPU Holder and depository agents must complete and return the "Declaration for Singapore Tax Purposes Form A and Form B (and its annexes)" to the Registrar's office by 5.00 p.m. on Friday, 20 August 2021 in order to receive the Distributions either at gross or at net (after deduction of tax at 10%) as described above.

IMPORTANT DATES AND TIMES

Date / Deadline

Event

9.00 a.m., Thursday, 5 August 2021

Units will be traded ex-distribution

5.00 p.m., Friday, 6 August 2021

Close of OUE C-REIT's Transfer Books and Register

of Unitholders and Transfer Books and Register of

CPPU Holder

5.00 p.m., Friday, 20 August 2021

Unitholders/CPPU Holder and depository agents

must have completed and returned the "Declaration

for Singapore Tax Purposes Form A and Form B" to

the Unit Registrar, Boardroom Corporate & Advisory

Services Pte. Ltd.

Friday, 10 September 2021

Payment of Distributions to Unitholders and CPPU

Holder

Should Unitholders/CPPU Holder have any queries in relation to these procedures, please contact:

Elaine Cheong

Senior Vice President, Investor Relations

Tel: +65 6809 8700

Email: elaine.cheong@ouect.com

By Order of the Board

Kelvin Chua

Company Secretary

OUE Commercial REIT Management Pte. Ltd.

(Registration Number: 201327018E)

(as manager of OUE Commercial Real Estate Investment Trust)

29 July 2021

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OUE Commercial Reit published this content on 29 July 2021 and is solely responsible for the information contained therein. Distributed by Public, unedited and unaltered, on 29 July 2021 10:26:09 UTC.