Distributions made by Real Estate Investment Trusts (“REITs”) listed on the Singapore Exchange to individuals, whether foreign or local, are tax exempt except where such distribution is derived by the individual through a partnership in Singapore or from the carrying on of a trade, business or profession. In this respect, the Inland Revenue Authority of Singapore (“IRAS”) has confirmed that all individuals will receive their distributions from MPACT without tax being deducted at source (“gross distributions”). Individuals who derive the distributions through a partnership in Singapore or from the carrying on of a trade, business or profession will be required to declare the distributions in their income tax returns notwithstanding that they received gross distributions as they are not eligible for the aforesaid tax exemption.

In addition, REITs’ distributions to qualifying non-resident non-individual investors made during the period from 18 February 2005 to 31 December 2025 (both dates inclusive) and qualifying non-resident funds made during the period from 1 July 2019 to 31 December 2025 (both dates exclusive) are subjected to a reduced rate of tax of 10%.

The Manager of MPACT has established an arrangement with the IRAS to allow eligible Unitholders to claim a back-end refund of tax over-deducted, if any, from income distributions made to them.

You can avail of this arrangement if you are:

1. A qualifying non-resident non-individual¹ or a qualifying non-resident fund² holding MPACT Units in your own name; or
2. an individual, a qualifying non-resident non-individual¹ or a qualifying non-resident fund² whose MPACT Units are held through a Depository Agent. Please approach your Depository Agent who will claim the refund on your behalf; or
3. a charity registered under the Charities Act 1994 or established by any written law, a town council, a statutory board, a co-operative society registered under the Co-operative Societies Act 1979, a trade union registered under the Trade Unions Act 1940 or an international organisation that is exempt from tax on such distributions by reason of an order made under the International Organisations (Immunities and Privileges) Act 1948, (collectively referred to as “Exempt Non-corporate Unitholders”). If your MPACT units are held through a Depository Agent, please approach your Depository Agent who will claim the refund on your behalf.

¹ A qualifying non-resident non-individual is one 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, but the funds used to acquire the MPACT Units are not obtained from that operation.

² A qualifying non-resident fund*** is one who is not a resident of Singapore* for income tax purposes, qualifies for tax exemption under section 13D, 13U or 13V of the Income Tax Act 1947 and:

1. who does not have any permanent establishment in Singapore (other than the fund manager in Singapore); or
2. who carries on any operation in Singapore through a permanent establishment** in Singapore (other than the fund manager in Singapore), but the funds used to acquire the MPACT Units are not obtained from that operation.

* A company is not a tax resident of Singapore if the management and control of its business is exercised outside Singapore during the respective calendar year in which the distribution was made and there is no intention to change the management and control of its business to Singapore.

** A permanent establishment is defined under the Income Tax Act 1947 as a fixed place where a business is wholly or partly carried on including a place of management, a branch, an office, a factory, a warehouse, a workshop, a farm or plantation, a mine, oil well, quarry or other place of extraction of natural resources, a building or work site or a construction, installation or assembly project. A unitholder shall be deemed to have a permanent establishment in Singapore if it: -

1. carries on supervisory activities in connection with a building or work site or a construction, installation or assembly project; or
2. has another person acting on the unitholder's behalf in Singapore who: -
   1. has and habitually exercises an authority to conclude contracts; or
   2. maintains stock of goods or merchandise for the purpose of delivery on its behalf; or
   3. habitually secures orders wholly and almost wholly for the unitholder or for such enterprises as are controlled by the unitholder.

*** A non-resident fund refers to a fund that is a non-resident company, a partnership where all the partners are non-residents, a trust administered by a non-resident trustee or a non-resident entity.

This refund arrangement applies to the following distributions:

1. where the beneficial owner of MPACT Units is an individual or an Exempt Non-Corporate Unitholder, distributions made by MPACT on or after 27 April 2011;
2. where the beneficial owner of MPACT Units is a qualifying non-resident non-individual, distributions made by MPACT during the period from 27 April 2011 to 31 December 2025 (both dates inclusive); and
3. where the beneficial owner of MPACT Units is a qualifying non-resident fund, distributions made by MPACT during the period from 1 July 2019 to 31 December 2025 (both dates inclusive).

Please note that MPACT's first distribution after listing was made on 1 September 2011.

If you are a qualifying non-resident non-individual, a qualifying non-resident fund or an Exempt Non-corporate Unitholder holding MPACT Units in your own name:

1. Download and complete Form R1. Use a separate Form R1 for each income distribution period.
2. Submit the duly completed Form R1, accompanied by the Subsidiary Income Tax Certificate (“SITC”) or the Account Statement/ Annual Dividend Statement (“ADS”) issued by the CDP which reflects the distribution in respect of which the claim for refund is made, to Boardroom Corporate & Advisory Services Pte. Ltd. at 1 Harbourfront Avenue, Keppel Bay Tower #14-07, Singapore 098632.

If you are an individual, a qualifying non-resident non-individual, a qualifying non-resident fund or an Exempt Non-Corporate Unitholder and you hold MPACT Units through Depository Agents, please liaise with your Depository Agent on your claim for refund. The claim will be made on your behalf by your Depository Agent.

If you are a Depository Agent and wish to claim for refund on behalf of beneficial owners who are individuals, qualifying non-resident non-individuals, qualifying non-resident funds or Exempt Non-Corporates:

1. Download and complete Form R2, including Annexes 1 to 3. Use a separate Form R2 for each income distribution period.
2. Submit the duly completed Form R2, accompanied by the SITC issued for the distribution in respect of which the claim for refund is made, to Boardroom Corporate & Advisory Services Pte. Ltd. at 1 Harbourfront Avenue, Keppel Bay Tower #14-07, Singapore 098632.
3. Email a soft copy of the completed Annexes to Boardroom Corporate & Advisory Services Pte. Ltd. at the following email address: srs.teamd@boardroomlimited.com.

You may submit the Forms and the accompanying SITCs or CDP Account Statement/ ADS to Boardroom Corporate & Advisory Services Pte. Ltd. at any time.

The Trustee of MPACT will collate the claims for refund submitted by Unitholders and the Depository Agents and make a claim for refund to the IRAS on a half-yearly basis. For example, all Forms received during the period ending 31 December 2022 will be submitted to IRAS sometime between January and April 2023.

Every claim for refund must be made to the IRAS within 4 years from the end of the year of assessment to which the claim relates. For example, for claim of refund in respect of distribution made by MPACT for the period from 1 April 2016 to 30 June 2016 (which relates to the year of assessment 2018), the claim must be submitted to the IRAS on or before 31 December 2022. Unitholders and the Depository Agents must ensure that the relevant Forms are submitted on a timely basis to allow the Trustee of MPACT to make the claim for refund within the prescribed time limit. The IRAS will not process any claim that is out of time.

The amount of tax over-deducted will be refunded only when the IRAS has refunded the amount to the Trustee of MPACT.