Tax Refund

TAX REFUND PROCEDURES FOR UNITHOLDERS

Background

Taxable income 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") allows REITs to make such distributions on a gross basis (i.e., without tax being deducted at source) to all individuals (excluding individuals who hold their units in REITs through partnerships). Individuals who derive their distributions from the carrying on of a trade, business or profession are not eligible for this tax exemption, and are required to declare the distributions in their income tax returns, notwithstanding that gross distributions are made to them.

In addition, taxable income distributions can also be made at gross (i.e., without tax deducted at source) to certain qualifying non-individual Unitholders while taxable income distributions made to qualifying non-resident non-individual Unitholders¹ and qualifying non-resident funds² are entitled to a reduced rate of withholding tax deduction of 10% for distributions made till 31 December 2030⁴.

In the event that tax has been wrongly deducted and accounted to the Comptroller of Income Tax ("CIT"), the CIT allows eligible Unitholders to claim a refund of the tax over-deducted through the trustee and the manager of the REIT, provided that these Unitholders have not made a claim for tax credit in respect of the same amount in their Singapore income tax return submission under section 46(1)(d) of the Income Tax Act 1947.

Eligible Unitholders of units in NTT DC REIT can therefore claim a tax refund from the CIT for tax that has been wrongly deducted through the Trustee and the Manager of NTT DC REIT.

The procedures for this tax refund claim are set out below.

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Which Unitholders are eligible for this tax refund?

Eligible Unitholders are:

1. Individuals holding NTT DC REIT Units through Depository Agents;
2. Qualifying non-resident non-individual Unitholders¹ or qualifying non-resident funds² holding NTT DC REIT Units in their own name or through Depository Agents; or
3. Exempt non-corporate Unitholders³ holding NTT DC REIT Units in their own names or through Depository Agents.

For other categories of Unitholders, they will need to claim a refund of the withholding tax over-deducted, if any, when filing their tax return.

Which distributions are eligible for the tax refund?

For qualifying non-resident non-individual Unitholders¹, qualifying non-resident funds² as well as beneficial owners who are qualifying non-resident non-individual Unitholders¹ and qualifying non-resident funds², the tax refund applies to taxable income distributions made by NTT DC REIT till 31 December 2030⁴.

For exempt non-corporate Unitholders³ and beneficial owners who are exempt non-corporate Unitholders³, the tax refund applies to taxable income distributions paid or to be paid on or after 14 July 2025.

Notwithstanding the above, please note that (1) all tax refunds are subject to the relevant claim being made within the applicable time limits (please refer to the section on the time limit for claim below); and (2) unitholders who have already made a claim for tax credit in respect of the corresponding amount in their Singapore income tax return submission under section 46(1)(d) of the Income Tax Act 1947 will not be eligible to claim for a tax refund.

How to make a claim?

1. If you are a qualifying non-resident non-individual Unitholder¹, a qualifying non-resident fund² or an exempt non-corporate Unitholder³ holding NTT DC REIT Units in your own name:

   1. Download and complete Form R1. Use a separate Form R1 for each distribution period.

   2. Submit the duly completed Form R1, accompanied by the Subsidiary Income Tax Certificate ("SITC") or the Annual Dividend Statement ("ADS") issued by the Central Depository (Pte) Ltd for the distribution in respect of which the claim for refund is made, to Boardroom Corporate & Advisory Services Pte. Ltd., 1 Harbourfront Avenue, #14-07 Keppel Bay Tower, Singapore 098632.

   Once you have submitted Form R1, you are not to make further claims for tax credit corresponding to the same refund claim in your income tax return submission (where applicable) under section 46(1)(d) of the Income Tax Act 1947.

2. If you are an individual, a qualifying non-resident non-individual Unitholder¹, a qualifying non-resident fund² or an exempt non-corporate Unitholder³ holding NTT DC REIT Units through Depository Agents, please liaise with your respective Depository Agent on your claim for tax refund. The claim will be made on your behalf by your Depository Agent.

3. If you are a Depository Agent and wish to make a claim for the tax refund on behalf of beneficial owners who are individuals, qualifying non-resident non-individual Unitholders¹, qualifying non-resident funds² or exempt non-corporate Unitholders³:

   1. Download and complete Form R2, including Annexes 1 to 3. Use a separate Form R2 for each distribution period.

      ID numbers such as Singapore NRIC number, passport number or foreign ID number are required for individuals who hold their units through Depository Agents.

   2. Submit the duly completed Form R2, accompanied by the SITCs issued for the distribution in respect of which the claim for refund is made, to Boardroom Corporate & Advisory Services Pte. Ltd., 1 Harbourfront Avenue, #14-07 Keppel Bay Tower, Singapore 098632.

   3. Email a soft copy of the completed Annexes to Boardroom Corporate & Advisory Services Pte. Ltd. at srs.teama@boardroomlimited.com.

   Once you have submitted Form R2, you are to inform your respective beneficial owners that they are not to make further claims for tax credit corresponding to the same refund claim in their income tax return submission (where applicable) under section 46(1)(d) of the Income Tax Act 1947.

When do we submit Form R1 or Form R2?

You may submit the forms (Form R1 / Form R2) and the accompanying SITCs or ADS to Boardroom Corporate & Advisory Services Pte. Ltd. at any time.

The Trustee and the Manager of NTT DC REIT will collate the claims for tax refund submitted by Unitholders / Depository Agents and make a claim for tax refund to the IRAS on a half-yearly basis (in March and September). For example, all forms received during the half-year ending 30 September 2026 are expected to be submitted to the IRAS in October / November 2026. Please use a separate form for each income distribution period.

Please note that the Trustee and the Manager of NTT DC REIT reserves the right to end the half-yearly tax refund process if it is deemed to be no longer necessary (e.g. change in legislation) with advance notice.

When will we receive the tax refund?

The tax refund will be paid out to eligible Unitholders / Depository Agents, subject to approval by the IRAS and upon receipt of the tax refund from the IRAS by the Trustee of NTT DC REIT. For Depository Agents, you can then proceed to make tax refunds to your respective beneficial owners.

The unit registrar will issue a letter for the refund, which will serve as evidence that the tax refund has been made.

Is there a time limit for the tax refund?

Every claim for tax 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 the claim of tax refund in respect of distributions made by NTT DC REIT for the period from 14 July 2025 to 30 September 2026 (which relates to the Year of Assessment 2027), the claim must be submitted to the IRAS on or before 31 December 2031.

Unitholders and Depository Agents must ensure that the relevant forms are submitted on time to allow the Trustee and Manager of NTT DC REIT to make the claim for tax refund within the prescribed time limit. The IRAS will not process any claim that has exceeded the 4 years time frame.

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