Taxation Information

Introduction

When you invest in Cromwell Property Group you acquire Cromwell Property Group stapled securities (ASX code: CMW). Each stapled security consists of a share in Cromwell Corporation Limited (“CCL”) and a unit in the Cromwell Diversified Property Trust (“DPT”).

In December 2006, CCL and DPT were stapled (referred to as the Stapling Transaction). This means that shares in CCL and units in DPT can only be transferred or traded together as Cromwell Property Group stapled securities on the Australian Securities Exchange. However, CCL shares and DPT units remain separate assets for taxation purposes.

Cromwell’s year end for tax purposes is 30 June.  The total annual distribution and tax components are advised in the Attribution Managed Investment Trust Annual (“AMMA”) Statement sent to securityholders in August each year.  Any dividends and franking credits from your shares in CCL and distributions in relation to your units in DPT need to be separately disclosed in your income tax return.

Attribution Managed Investment Trust Regime

The Responsible Entity of DPT made an irrevocable election to be an Attribution Managed Investment Trust (“AMIT”) for all years beginning from 1 July 2017.

Your AMMA Statement provides the components of the distribution that have been attributed to you each financial year.

For tax purposes, the distribution from DPT comprises separate components including interest income, taxable other income, capital gains and foreign income.  Your attributed amounts of these components are outlined on your AMMA Statement.

Australian resident taxpayers include in their assessable income their attributed amount of DPT’s determined trust components (including any net capital gains of DPT). These attributed amounts are included in a resident taxpayer’s assessable income for tax purposes irrespective of when the cash in respect of the attributed amounts is received.

For more information regarding the AMIT regime please visit the Australian Taxation Office’s website at www.ato.gov.au.

Income Tax Components

Stapled security holders who receive distributions from Cromwell will be sent an Annual Tax Statement and Income Tax Guide for the relevant income tax year. The Annual Tax Statement details the tax amounts to be included in each stapled security holder’s income tax return. The Annual Tax Statement will be provided in August each year, along with the Income Tax Guide (See "Income Tax Guides" below).

A duplicate copy of your recent Annual Tax Statements can be downloaded, free of charge by clicking on the link to Link Market Services at: www.cromwell.com.au/registry. Alternatively, for a replacement statement contact Link Market Services Limited on 1300 550 841 (within Australia) or +61 2 8280 7124 (outside Australia) between 8.00am and 7.30pm, EST Monday to Friday. A replacement statement charge may be payable to Link Market Services.

Stapled securityholders should rely on their Annual Tax Statement when completing their income tax return. For information purposes only, the below document outlines the applicable income tax component percentages for past income tax years.

Income Tax Guides

The below Tax Guides are provided to assist Australian resident individual Cromwell Securityholders to understand their Annual Taxation Statement and to prepare their income tax returns.

Tax Guides (since DPT became an AMIT)

Tax Guides (prior to DPT being an AMIT)

Distribution Components for Non-Resident Withholding Tax Purposes

The below fund payment disclosures are provided for the purposes of the withholding tax obligations contained in Subdivision 12-H of the Taxation Administration Act 1953 (Cth). These documents should not be used for any other purpose. In particular, Australian resident stapled securityholders should not rely on these disclosures for the purposes of completing their income tax returns. Securityholders should rather refer to their Annual Tax Statement or AMMA Statement  when completing their income tax returns.

Fund Payment Disclosures

Capital Gains Tax

When you invest in the Cromwell Property Group you acquire stapled securities. Each stapled security consists of a share in Cromwell Corporation Limited ("CCL") and a unit in Cromwell Diversified Property Trust ("DPT"). CCL shares and DPT units are separate assets for capital gains tax purposes.

Securityholders should refer to the ATO’s document titled "Stapled Securities” to determine their capital gains tax (“CGT”) obligations.

For capital gains tax purposes stapled securityholders need to apportion the cost of each stapled security and the proceeds on sale of each stapled security on a reasonable basis over the CCL shares and DPT units. One possible method of apportionment is on the basis of the relative net tangible assets of CCL and DPT. Details of the net tangible assets of CCL and DPT are set out in the tax guides.  In particular stapled security holders should be careful to adjust their tax cost base of their units in DPT for tax deferred and/or AMIT cost base net amount excess/shortfall adjustments as outlined in their Annual Tax Statement or AMMA Statement provided each year.

This is general information, not tax advice

The above information has been prepared for general information only and should not be relied upon as tax advice. This information should be read in conjunction with the Australian Taxation Office’s ("ATO") instructions and publications. An investment in stapled securities can give rise to complex tax issues and each investor’s particular circumstances will be different. As such we recommend, before taking any action based on this document, that you consult your professional tax adviser for specific advice in relation to the tax implications. This document does not constitute financial product or investment advice, and in particular, it is not intended to influence you in making decisions in relation to financial products including Cromwell Property Group stapled securities. While every effort is made to provide accurate and complete information, Cromwell Property Group does not warrant or represent that this information is free of errors or omissions or is suitable for your intended use and personal circumstances. Subject to any terms implied by law which cannot be excluded, Cromwell Property Group accepts no responsibility for any loss, damage, cost or expense (whether direct or indirect) incurred by you as a result of any error, omission or misrepresentation in the information provided.