Special liens

1. Special tax on distributed profits

1. Tax rate

   The SOCIMI will be taxed at a special rate of of 19 percent on the full amount of dividends or shares in profits distributed to the partners when:

   • The participation in the share capital of the entity is equal to or greater than 5 percent and

   • Said dividends at the headquarters of its partners are exempt or taxed at a rate of less than 10 percent.

   This tax will be considered share of the Corporate Tax .

   This tax will not apply when the partner who receives the dividend is an entity to which Law 11/2009 applies.

   Nor will it be applicable when dividends or shares in profits are received by non-resident entities whose main corporate purpose is the holding of shares in the capital of other SOCIMIs or in that of other non-resident entities in Spanish territory that have the same corporate purpose. that those and that are subject to a regime similar to that established for SOCIMIs in terms of the mandatory, legal or statutory, profit distribution policy, with respect to those partners who:

   • They have a participation equal to or greater than 5 percent in the share capital of those, and

   • Be taxed on such dividends or participation in profits, at least, at the tax rate of 10 percent .

2. Accrual

   This tax will accrue on the day of the profit distribution agreement by the general meeting of shareholders or competent body.

3. Self-assessment and deposit

   The amount of the special tax must be self-assessed and entered through form 217 approved by Order HFP /1922/2016, of December 19, within a period of two months from the accrual date .

   Your presentation will be mandatory electronically .

   This special tax does not apply and, therefore, there will be no obligation to present form 217 in the following cases:

   • When the dividend is received by an entity to which Law 11/2009 applies .

   • When dividends or shares in profits are received by non-resident entities whose main corporate purpose is the holding of shares in the capital of other REITs or in that of other non-resident entities in Spanish territory that have the same corporate purpose as those and that are subject to a regime similar to that established for SOCIMIs in terms of the mandatory, legal or statutory, profit distribution policy, with respect to those partners who:

     • They have a participation equal to or greater than 5 percent in the share capital of those, and

     • Be taxed on such dividends or participation in profits, at least, at the tax rate of 10 percent .

2. Special tax on undistributed profits

1. Tax rate

   With effect for tax periods beginning on or after January 1, 2021, the SOCIMI will be taxed at a rate of 15 percent on the amount of the profits obtained in the year that is not subject to distribution , in the part that comes from income that has not been taxed at the general tax rate tax on Corporation Tax nor is it income covered by the 3-year reinvestment period regulated in letter b) of article 6.1 of Law 11/2009.

   This tax will be considered share of the Corporate Tax .

2. Accrual

   This special tax will accrue on the day of the agreement to apply the results of the year by the general meeting of shareholders, or equivalent body.

3. Self-assessment and deposit

   The amount of the special tax must be self-assessed and entered through form 237 approved by Order HFP /1430/2021, of December 20, within a period of two months from the accrual date .

   Your presentation will be mandatory electronically .