Distribution obligation

Activity rules

The Fund, being a so called closed fund for mutual account (‘closed FGR’ in Dutch), is tax transparent for Dutch corporate income tax and dividend withholding tax purposes. and therefore, all activities are attributable to the investors for tax purposes. A foundation (“Stichting Legal Owner”) will hold the legal titles of the real estate and the shares of the subsidiaries. To qualify as a tax transparent FGR, the transfer of the Fund-participations solely occurs via a purchase and re-issuance by Fund FGR.