MRM - 2018 Registration document

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General information on the issuer and its capital

Consolidated financial statements for the financial year ended 31 December 2018

Note 6

Tax

6.1 Group tax status Since 2008, M.R.M. has been registered as an SIIC (real estate investment trust) with a scope covering all the Group’s entities. SIIC status grants tax exemption on: • profits from the letting of buildings and the subletting of buildings under a property leasing; • capital gains on the disposal of buildings, of rights belonging to property leasing contracts, of equity investments in partnerships, or of equity investments in subsidiaries having opted for the SIIC tax regime; • dividends paid by subsidiaries subject to the SIIC tax regime. In exchange for this exemption, SIICs must distribute: • 95% of exempted profits from letting; • 60% of capital gains on the disposal of buildings or of certain equity investments in real estate companies; • all dividends paid by subsidiaries having opted for the SIIC tax regime. SIIC status entailed paying a reduced exit tax of 16.5% on latent capital gains relating to the buildings and shares of partnerships not subject to corporate tax. The Group has paid its outstanding exit tax since 15 June 2012. 6.2 Tax expense As a result of adopting SIIC status, which exempts the Company from corporate tax, no deferred tax has been recognised on activities within the scope of this regime.

The Group is nevertheless still liable for corporate tax on activities falling outside the scope of the SIIC regime. The Group recognised no tax expense for the 2018 financial year. 6.3 Deferred tax Deferred taxes are recorded for activities and companies subject to corporate tax according to the variable method up to the temporary differences between the tax base of assets and liabilities and their carrying amount in the consolidated financial statements. Deferred taxes are calculated using the tax rates (and tax regulations) that were adopted at the end of the reporting period and which are expected to come into force when the deferred tax asset in question is realised or the deferred tax liability is settled. Deferred tax assets are recognised only to the extent that a taxable future asset allowing temporary differences to be attributed is likely to be realised. Deferred taxes are recorded on the basis of temporary differences tied to equity investments in subsidiaries or affiliates, except for when the Group controls the scheduled reversal of these temporary differences and the reversal is unlikely to occur in the near future. On account of the Group’s SIIC status, no corporate tax is due on the letting of buildings, either directly or indirectly through income received from subsidiaries, and no deferred tax was recognised as of 31 December 2018. Likewise, capital gains on the disposal of buildings or of shares in subsidiaries subject to the same regime are exempt. Given that there was no temporary difference between the tax base of assets and liabilities falling outside the scope of the SIIC regime and their carrying amount in the consolidated financial statements, no deferred tax asset was recognised in 2018.

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M.R.M. 2018 REGISTRATION DOCUMENT