Canada Mutual fund trust. Real or immovable 95% of total fair market 75% of REIT revenue must No minimum distribution (but REIT not on distributed property situated in value of assets must be be attributable to or to avoid tax at REIT level all of income. Listed, at least Canada (excluding Canadian real or property capital gains. its income must be 150 unit holders. Residents at normal rates. — depreciable property moveable property or distributed). 90% of gross REIT revenues Nonresident unit holders — except buildings). certain financial must be from rent or other 25% withholding tax (DTAs may instruments. (Foreign property gains from property and reduce to 15%). investment exempt from 75% of REIT’s equity other passive income. SIFT). value must be real property and certain other Subsidiary entities, assets. including internal management company. 10% safe harbour for nonqualifying REIT property. Germany Company. Real estate in Germany 75% of assets must relate 75% of earnings must relate Must distribute 90% of profits. company exempt. GREIT — and abroad. to real estate assets. to real estate assets. subsidiaries taxable. — Listed. Wholly owned service Wholly owned service Wholly owned service 26.4% withholding tax on At 15% shares corporation. corporation assets must corporation earnings must dividends (final tax for resident must be publicly not exceed 20% of total not exceed 20% of total individuals, corporate taxpayers listed, and no assets. earnings. claim a credit). (DTAs may shareholder can reduce to 15% for nonresidents). hold more than 10%. Hong Kong Unit Trusts. Real estate (not vacant 75% of assets must be Must distribute 90% of audited REIT exempt, except subject — land or property income generating annual net income after tax. to property tax on rentals. Listed. development). properties. Investors not subject to any — No minimum Special purpose Hong Kong tax. investors. vehicles may be used for hotels, recreation parks, or serviced apartments.
Canada Mutual fund trust. Listed, at least 150 unit holders. Real or immovable property situated in Canada (excluding depreciable property except buildings). (Foreign property investment exempt from SIFT). Subsidiary entities, including internal management company. 95% of total fair market value of assets must be Canadian real or moveable property or certain financial instruments. 75% of REIT’s equity value must be real property and certain other assets. 10% safe harbour for nonqualifying REIT property. 75% of REIT revenue must be attributable to or property capital gains. 90% of gross REIT revenues must be from rent or other gains from property and other passive income. No minimum distribution (but to avoid tax at REIT level all of its income must be distributed). REIT not on distributed income. Residents — at normal rates. Nonresident unit holders — 25% withholding tax (DTAs may reduce to 15%). Germany Company. Listed. At 15% shares must be publicly listed, and no shareholder can hold more than 10%. Real estate in Germany and abroad. Wholly owned service corporation. 75% of assets must relate to real estate assets. Wholly owned service corporation assets must not exceed 20% of total assets. 75% of earnings must relate to real estate assets. Wholly owned service corporation earnings must not exceed 20% of total earnings. Must distribute 90% of profits. company — exempt. GREIT subsidiaries — taxable. 26.4% withholding tax on dividends (final tax for resident individuals, corporate taxpayers claim a credit). (DTAs may reduce to 15% for nonresidents). Hong Kong Unit Trusts. Listed. No minimum investors. Real estate (not vacant land or property development). Special purpose vehicles may be used for hotels, recreation parks, or serviced apartments. 75% of assets must be income generating properties. Must distribute 90% of audited annual net income after tax. REIT — exempt, except subject to property tax on rentals. Investors — not subject to any Hong Kong tax.
C2017-009_Stapled_Structures.docx