Annual Report 2025 151 Notes to the Financial Statements 31 December 2025 (ii) companies incorporated and tax resident in Singapore; (iii) Singapore branches of foreign companies which have presented a letter of approval from the IRAS granting waiver from tax deducted at source in respect of distributions from the Trust; (iv) non-corporate Singapore constituted or registered entities (e.g. town councils, statutory boards, charitable organisations, management corporations, clubs and trade and industry associations constituted, incorporated, registered or organised in Singapore); (v) Central Provident Fund (“CPF”) members who use their CPF funds under the CPF Investment Scheme and where the distributions received are returned to the CPF accounts; and (vi) individuals who use their Supplementary Retirement Scheme (“SRS”) funds and where the distributions received are returned to the SRS accounts. The Trustee and the Manager will deduct tax at the reduced concessionary rate of 10.0% from distributions made during the period from 18 February 2005 to 31 December 2030 (both dates inclusive) made out of the Trust’s taxable income that is not taxed at the Trust’s level to beneficial Unitholders who are qualifying foreign non-individual investors. A qualifying foreign non-individual investor is one who is not a resident of Singapore for income tax purposes and: (i) who does not have a permanent establishment in Singapore; or (ii) who carries on any operation in Singapore through a permanent establishment in Singapore, where the funds used to acquire the Units in the Trust are not obtained from that operation. With reference to the global minimum top-up tax under Pillar Two, the Group has adopted Amendments to FRS 12: International Tax Reform – Pillar Two Model Rules upon their release on 23 May 2023. The Group has applied a temporary mandatory relief from deferred tax accounting for the impacts of the top-up tax and accounts for it as a current tax when it is incurred. Accordingly, the Group neither recognises nor discloses information about deferred tax assets and liabilities related to Pillar Two income taxes. (ii) Sales tax Revenues, expenses and assets are recognised net of the amount of sales tax except: • Where the sales tax incurred on a purchase of assets or services is not recoverable from the taxation authority, in which case the sales tax is recognised as part of the cost of acquisition of the asset or as part of the expense item as applicable; and • Receivables and payables are stated with the amount of sales tax included. 3.9 Provisions Provisions are recognised when the Group has a present obligation (legal or constructive) as a result of a past event, it is probable that an outflow of resources embodying economic benefits will be required to settle the obligation and the amount of the obligation can be estimated reliably. Provisions are reviewed at the end of each reporting period and adjusted to reflect the current best estimate. If it is no longer probable that an outflow of economic resources will be required to settle the obligation, the provision is reversed. 3. Material Accounting Policy Information (continued) 3.8 Taxation (continued) (i) Current tax and deferred tax (continued)
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