Global REIT Comparison

U.S.

Australia

Netherlands

Canada

Belgium

Singapore

Japan

France

Hong Kong

Malaysia

Korea

Taiwan

Management Internal or External

Either

Either

Internal

Internal

Either

External

External

Either

Either

External

Either

Either

Investment Restrictions

Real Estate Investments

75%+

50%+ of revenue from rent*

100%

80%+

100%

70%+

75%+

Flexible

100%

50–75%

70%+

75%+

Overseas Investment

OK

OK

OK

OK

Prohibited

OK

OK

OK

OK

OK but approvals required

OK

OK but approvals required

Development

OK

OK

Minimal

OK

Minimal

20% of total assets

OK (but 50%+of assets must be income) producing)

Prohibited

Prohibited

OK (limit to 30% of equity)

OK

Prohibited

Gearing Limit

None

None

60% property assets

None

50% of total assets

35% total asset***

None

None

45% of total assets

35%

Limit to 200% of equity

35%

Payout

90%+ of taxable income (post deprec.)

100% of taxable income(post deprec.)

100% of fiscal earnings

85% of distributable cash (pre-deprec.)

80% of taxable income and net debt paydown

100% of taxable income (no deprec.)

90%+ of taxable income (post deprec.)

85% of taxable income from rentals, 50% of capital gains

90% + of net income after tax (no deprec.)

No restrictions(but undistributed earnings is taxed at 28%)

90%+ of equity less capital and reserve

100% of distributable income (post) expense and reserve)

Closed Ended**

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Closed ended mostly, opened end need gov.’s approval

Listed/Unlisted**

Both

Both

Both

Listed

Listed

Listed

Listed

Listed

Listed

Both

Both

Both

Tax Transparency

Yes

Yes

Yes^

Yes

Yes^

Yes

Yes

Yes^

No**

Yes

Yes

Yes+

Notes: * This is a condition of entry into the LPT index, not a regulatory requirement. ^Taxed at source on overseas income and non-exempt activities such as development (France only). ** Not needed as there is no tax on dividends in HK. ^^Currently Germany is the only country with tax transparent option that is unlisted and open ended that is available to both tax paying and tax exempt investors. ***With ›35% with an A rating. ^^^ Capital gains from the tax -exempt portion can be distributed in-line with tax treatment of rent. + No tax on capital gain, but 6% on dividend gain. Source: UBS