Australian Real Estate Investment Guide. savills.com.au

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1 Australian Real Estate Investment Guide savills.com.au

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3 the investment process The Property Acquisition Process With the help of a real estate advisor, once the Investor has identified a property that fulfils the investment criteria, negotiations are initiated and the advisor will submit an offer on the Investor s behalf. If the offer is accepted the agreed terms will be documented in the Heads of Terms, which are subject to contract, in other words non-binding. Once Heads of Terms are agreed, the vendor will provide the investor, property and legal advisors with various legal and property documentation that initiate the purchaser s due diligence process. Traditionally, the purchaser has 30 working days to complete their due diligence, subject to negotiation. The technical due diligence will typically include a survey, valuation report, credit checks and inspection. The legal due diligence will focus on the acquisition contract, the building and the leases attached to it and searches (enquiries to seller and public bodies). The commercial due diligence focuses on the commercial aspects of the investment to ensure that the investment meet the return and risk profile of the Investor. Once the due diligence is satisfactorily completed and the contract is agreed, parties would then exchange contracts. At this stage the purchaser pays a deposit (normally 5% - 10% of the purchase price). Once contracts have been exchanged the purchase is legally bound by the terms of the contract. Fees and Taxes For an acquisition we would normally assume the following fees : Item % of Purchase Price Assuming stamp duty land tax 4% %% Advisory fees 1.0% Legal fees 0.5% Total acquisition fees 5.5% % The Goods and Services Tax (GST) is currently at 10% and is generally charged on goods and services. It is possible for an Investor to register for GST and therefore fully recover GST and structure transactions to avoid paying GST on the purchase price. 3

4 the investment process The Investment Period Once acquired, the Investor is responsible for the asset and property management of the building. Average lease terms in Australia are around five years. Larger tenants favour 7-10 year lease terms. Most leases have annual rent review provisions and cannot be broken. Commercial Leases The most common kinds of commercial leases are: Multi-tenant office leases Single-tenant lease Registration Generally, leases involving lease terms (in some Australian jurisdictions, including any options to renew the lease) that exceed a prescribed term for short-term leases must be registered on a public register with the relevant government authorities. A short-term lease (the concept of which differs between jurisdictions, but in most jurisdictions this is a lease of three years or less) does not need to be registered. This is usually a lease within a high-rise office building, where different tenants have leased premises within a building and will pay a rental amount, generally monthly, in addition to a proportionate share of the landlord s expenses of repairing and maintaining the building and the common areas (eg gardens or kitchens). Generally, the landlord is responsible for the maintenance and repair of the common areas of the building, which all of the tenants and the public are able to access. This usually involves a single tenant, which has exclusive use of the entire property. Generally, single tenants often have the responsibility to maintain all of the property and pay nearly all costs related to the property. Sometimes this can extend to structural and capital repairs, depending on the lease terms. Retail lease Retail leases typically exist in multi-tenant retail shopping centres and often have unique legislation governing them. Basic Terms of Commercial Leases There is no minimum or maximum term for a commercial lease. The duration of the lease term can be for any number of years or up to a fixed date. However, retail leases have a minimum term, inclusive of options. Measurable Space The measurable space of the leased premises is of particular importance for the calculation of the rent payable when the premises are initially leased and upon rent review, and also for the calculation of the proportion of the operating expenses (called outgoings). Operating Expenses The tenant is often obliged to pay for certain costs of the landlord operating, maintaining and repairing the building. When there are multiple tenants, each tenant pays its proportionate share of those costs. It is common practice for the costs to be charged to the tenant per square metre of the measurable space leased. 4

5 Savills Cross Border Investments oversees sales and investments in Australia s capital cities, and ensures diverse client property requirements are met with timely delivery and optimum results. 5

6 additional concepts in commercial leases Transfers A tenant is able to transfer its leasehold right to occupy the real estate to a third party through an assignment of the lease to a third party or a sublease of the existing lease to a third party as a subtenant. Options to Renew It is common for a lease to contain an option for the tenant to renew the lease for an additional term, however this must be negotiated between the parties. Usually the tenant is provided a certain time period prior to the expiration of the lease term to notify the landlord that they wish to exercise the option to renew the lease for an additional term. Asset Management Property and asset management are key activities during the investment period to maintain and possibly increase the capital and rental values of the property. Property Management is a complicated and broad discipline, covering everything from technical services and energy management to tenancy agreements. For overseas Investors that retain Savills as an asset manager, it provides the comfort that there is a dedicated team, who have the full resource of Savills behind them, that is looking after the investment and that will at all times monitor performance and propose necessary steps to enhance value. Effective, efficient property management can make a fundamental difference to the success of an investment. Savills expertise covers all areas of asset, property and facilities management and property accounting. Included in the services we provide are strategies to maximise investment performance, health and safety assessments and income collection and reporting. From specifications of a diverse range of services to ongoing facilities management and support services, our offices around the world provide quality, cost effective and sustainable facilities management solutions, tailored to the needs of our clients. The extent of the property advisors role will very much depend on the needs of the client and the type of asset that has been acquired. The Asset Disposal Process The disposal process comprises several key activities. An agent will review the market, undertake a detailed due diligence on the property, advise on an indicative price and prepare the marketing material. Based on market knowledge and understanding of Investors requirements, the agent will place the asset in the right market segment and to the right potential buyers. Fees and Taxes For an acquisition we would normally assume the following fees : Item % of Purchase Price Advisory fees 0.5% - 1.0% Legal fees 0.5% Total disposal fees 1.0% - 1.5% 6

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8 real estate ownership structures The choice of investment vehicle depends on whether the activity is investment (buy or develop and hold long term) or trading (buy/ develop and sell). The identity and status of any counterparties and co-investors are also relevant to the choice of structure. Foreign controlled companies trading in Australia are subject to the same operational requirements as Australian owned corporations and there are no legal restrictions on foreign ownership or occupation of real estate, or on foreign guarantees or security for ownership or occupation. Furthermore, there are no exchange control restrictions relating to the transfer of income or capital. How land is held in Australia Throughout Australia, there are two legal structures in which real estate is directly owned: freehold title and leasehold title. Owners of freehold title benefit from the absolute ownership of their land for an indefinite period of time. A leasehold title confers rights of exclusive possession and use, pursuant to specific legislation. Some Crown leasehold titles are perpetual in nature and other leaseholds are granted for fixed periods of time. Both freehold title and Crown leasehold title are subject to government powers of resumption, applicable laws governing the manner of use of their property (such as building regulations and town planning laws) and contractual arrangements freely bargained for by the holder of the title. Owners of freehold title and Crown leasehold title are able to grant leases of the property to third parties. The most commonly recognised interests in Australian land are detailed as follows. Freehold estate in fee simple This is the most common form of land ownership in Australia, and represents the most complete ownership interest available to persons other than the Crown. A fee simple estate is of unlimited duration. Most urban land is now held under the torrens title system. Leasehold interest Leasehold interest is the interest which a tenant or lessee acquires from the owner of the land to use and occupy the land for a limited period. Most commercial leases are for a fixed period of time. Generally, where the land is owned by the Crown, a person may take a long-term (often 99 years) leasehold interest from the Crown. Leasehold interests are generally required to be registered. Options to extend the term of the lease may also be negotiated. Ownership by foreigners There are some restrictions on foreign investment although generally, the Australian Government recognises that foreign real estate investment can enhance Australia economically. Foreign investment policy in Australia is regulated by the Foreign Acquisitions and Takeovers Act 1975 (Cth) (FATA), the Foreign Acquisitions and Takeovers Regulations 1989 (Cth). FATA and allow the Government to scrutinise proposed purchases by foreign persons of certain categories of Australian real estate. Other interests Other types of interest in land which may be registered include: mortgage interests which generally secure repayment of a loan or other financing arrangements options to acquire land easements which generally convey a right to use a particular part of someone else s land for a specific purpose, but not to occupy the land restrictive covenants a covenant given by the owner of one parcel of land to the owner of another parcel of land, by which the first owner agrees not to use their land in a particular way, for the benefit of the second owner; for example, an agreement by one owner not to build any structures which would impede the neighbouring owner s views. 8

9 Native title Native title was first recognised in Australia in 1992, when the High Court of Australia found that the traditional Aboriginal owners held native title over certain land. A national scheme, implemented through legislation in each state and territory, governs the validity of land dealings affecting native title and establishes a process to deal with native title claims. Native title rights can be compulsorily acquired or surrendered under law, but cannot be transferred. Although native title is most relevant to non-freehold land and Crown- or Commonwealth-owned land, a prudent buyer will take native title into account in relation to most land dealings. Regulation of Foreign Investment While there are some restrictions on foreign investment generally, the Australian Government recognises that foreign real estate investment can enhance Australia economically and socially. Accordingly, Australia s foreign investment regime is based on ensuring foreign investment is consistent with Australia s national interest. Foreign investment policy in Australia is regulated by the Foreign Acquisitions and Takeovers Act 1975 (Cth) (FATA), the Foreign Acquisitions and Takeovers Regulations 1989 (Cth) and other requirements set out by Ministerial Statement. FATA and its related regulations allow the Government to scrutinise proposed purchases by foreign persons of shares in companies incorporated or having assets in Australia and Australian real estate. The FATA regime is administered by the Federal Treasurer and the Foreign Investment Review Board (FIRB). FIRB is a non-statutory advisory body that examines foreign investment proposals, advises the Treasurer on whether the proposals are compliant with Australia s foreign investment policy and assists foreign investors in ensuring their proposals comply with government policy. Contracts All contracts which are being used by overseas investors for the purchase of Australian real estate for which FIRB approval is required must be made conditional upon FIRB approval (unless approval has already been granted). Contracts should provide for a minimum of 40 days from the date of lodgement for a decision from FIRB. For any properties being purchased at auction, prior FIRB approval must be obtained. Significant Investor Visa Regime The Australian Government has introduced a Significant Investor Visa, allowing high net worth individuals to apply for an Australian visa on the basis of a minimum investment in Australia of $5 million. Direct or indirect investments in Australian real estate are a qualifying category of permitted Investment. Proposals relating to urban land Overseas entities wanting to acquire urban land (including interests that arise via leases, financing and profit-sharing arrangements) must make a proposal to FATA. Proposals must be made in regard to the following: developed non-residential commercial real estate, where the property is subject to heritage listing, valued at A$5 million or more (in the case of both US and non-us investors); developed non-residential commercial real estate, where the property is not subject to heritage listing, valued at A$50 million or more in the case of non-us investors, or A$1,004 million or more in the case of US investors; accommodation facilities, valued at A$50 million or more; vacant real estate irrespective of value; residential real estate irrespective of value (subject to certain exceptions as outlined below); shares or units in Australian urban land corporations or trust estates, irrespective of value, must be approved by the Treasurer before they can be implemented and should be presented to FIRB in advance. Failure to notify may result in an order for compulsory divestment. You do not need prior approval to acquire residential real estate if you are: an Australian citizen living abroad; an overseas citizen purchasing, as a joint tenant, with your Australian citizen spouse; an overseas citizen who holds a permanent resident visa; a New Zealand citizen. Proposals relating to rural land The definition of rural land includes all land that is used wholly and exclusively for carrying-on a substantial business of primary production. A substantial business of primary production must have a commercial purpose or character and be involved in activities relating to the cultivation of land, animal husbandry/farming, horticulture, fishing, forest operations, viticulture or dairy farming (but does not include vacant land, hobby farms, land used for stock agistment or mining). Proposed acquisitions of rural land valued at A$248 million or more (or the relevant threshold for US investors) must be approved by FIRB. 9

10 10 Savills Cross Border Investment team works closely with all the Savills investment teams around the region on high profile sales, instructions of single assets and portfolios across sectors and often in multiple countries.

11 real estate ownership structures Types of Entities The type of entity used to acquire the Australian real property will often determine the Australian tax implications. Commonly, entities or a combination of entities such as companies, trusts, limited partnerships and joint ventures may be used to acquire Australian real property. Also, stapled structures (where investors hold interests in two or more entities and these securities cannot be bought or traded separately) are frequently used. Companies Companies are treated as a separate legal entity. A tax rate of 30% currently applies to both Australian resident companies and foreign companies. Generally, losses generated by companies are carried forward, provided certain conditions are satisfied and offset against future income. Trusts Trusts are generally treated as flowthrough entities. The trustee of the trust will not be taxed on the net income of the trust, provided that unitholders/ beneficiaries are presently entitled to all the income of the trust. Partnerships Generally, partnerships that are not limited liability partnerships are also treated as flow-through entities. However, unlike trusts, partnerships facilitate the flowthrough of both net income and net losses of the partnership to the partners. Unlimited partnerships bring with them practical difficulties, including the unlimited liability of the underlying partners. 11

12 taxation Foreign resident individuals are generally taxed on all income and capital gains from Australian sources, subject to specific exemptions. The maximum tax rate for foreign resident individuals is currently 45% for the year ended 30 June 2013 and this tax rate applies for income greater than AU$180,000. For capital gains, tax is payable only on 50% of capital gains arising from the disposal of Australian real property where certain residents or foreign investors (such as individuals and certain trusts) have held the real estate for more than 12 months. This is referred to as the CGT discount. Foreign companies are generally taxed on income and capital gains from Australian sources. A tax rate of 30% applies to both Australian resident companies and foreign companies. Tax legislation In Australia, power to levy tax exists at both commonwealth (ie, federal) and state levels. The federal government levies taxes such as income tax, and goods and services tax (GST). Taxes levied by state governments include stamp duty, land tax and payroll tax as well as transaction duty, fees and charges on certain kinds of business transactions. At the federal level, taxation is administered by the Australian Taxation Office (ATO). At the state and territory level, the relevant taxation authority is the State Revenue Office of the applicable state or territory. Stamp duty Stamp duty is a tax imposed at the state/ territory level. As a result, the stamp duty payable on a purchase of land will depend on where the land is situated. Stamp duty may also be payable on the purchase of shares in a company, particularly where the company is land rich. Stamp duty is generally charged at an incremental rate, based on the higher of the market value of the property transferred and the GST-inclusive consideration. Certain exemptions and concessions may be available. Stamp duty on land acquisitions in New South Wales is currently charged at a rate of between 1.25% and 7.0%; however, for the latest rates see table below. Stamp duty is generally payable by the purchaser, either by law or by commercial agreement, but in some jurisdictions the seller and purchaser are jointly and severally liable. The transfer of title to land cannot be registered until stamp duty has been paid. Land tax Land tax is also imposed at the state/ territory level. As a result, the rate of land tax, the threshold at which it becomes payable and the date on which it is assessed and paid will depend on where the land is situated. Generally, land tax is payable by the current owner as of 31 December or 30 June of the current year, and is assessed on the unimproved land value. Certain exemptions may be available (for example, land tax is generally not payable on a principal place of residence). The current maximum marginal rates of land tax for commercial property are shown in the table 2. Land tax is often recoverable from the Tenant in Commercial Offices. Corporation tax The tax rate for public and private companies, resident and non-resident, is currently 30%. 02 Current maximum marginal rates of land tax for commercial property State/territory Threshold (A$) Rate Department New South Wales 2,482,000 A$ % of land value Office of State Revenue Northern Territory Not payable Queensland 5,000,000 A$75, for each A$1 more than A$5,000,000 Office of State Revenue South Australia 1,052,001 A$10,695 + A$3.70 for every A$100 or fractional part of A$100 over A$1,052,000 Revenue South Australia Tasmania 350,000 A$1, % of amount above A$350,000 State Revenue Office Victoria 3,000,000 A$24, % of amount above A$3,000,000 State Revenue Office Western Australia 11,000,000 A$126, of each A$1 in excess of A$11,000,000 Office of State Revenue Source: ATO *Information current as of 17 May Note that different marginal rates may apply, depending on property type and value. Please refer to the applicable State or Territory revenue office website for up-to-date information. 12

13 Income tax Individuals, trustees, superannuation funds and companies deriving income from an Australian source must apply to the ATO for an Australian tax file number and must lodge an annual tax return with the ATO. Entities which carry on an enterprise in Australia also require an Australian business number. Income tax is payable by individuals, trustees (in certain circumstances), superannuation funds and companies. Australian income tax is imposed on a single measurement of taxable income, which is calculated as the sum of assessable income derived by the taxpayer during the relevant year of income less allowable deductions, ie, Taxable Income = Assessable Income Allowable Deductions Australian tax residents are generally liable to pay income tax in respect of their worldwide assessable income, whereas non-australian tax residents only pay tax on that part of their income which is derived from sources in Australia. However, this principle may be subject to the application of double taxation agreements (DTAs) which Australia has entered into with a number of other countries (please refer to the section headed Withholding tax overleaf for a list of countries). Taxation rates for individuals differ, depending on whether the individual is an Australian tax resident or not. The marginal rates of taxation applicable for Australian tax residents for the financial year from 1 July 2012 to 30 June 2013 are shown in Table 3. In addition, individual Australian tax residents must pay a Medicare Levy of 1.5% of taxable income, subject to lowincome thresholds, phase-in limits and surcharges for individuals without private health insurance. This is anticipated to rise to 2% to fund the National Disability Insuarance Scheme from July 1, The marginal rates of taxation applicable for non-australian tax residents for the financial year from 1 July 2012 to 30 June 2013 are shown in Table Income tax rates for Australian residents Taxation income (A$) Marginal tax rate (%) Tax on this income 0 18,200 0 Nil 18,201 37, for each A$1 over A$18,200 37,001 80, A$3, for each A$1 over A$37,000 80, , A$17, for each A$1 over A$80, , A$54, for each A$1 over A$180, Income tax rates for non-australian residents Taxation income (A$) Marginal tax rate (%) Tax on this income 0 37, for each A$1 37,001 80, A$10, for each A$1 over A$37,000 80, , A$23, for each A$1 over A$80, , A$60, for each A$1 over A$180,000 13

14 managed investment trust (MIT) Equity Investment Through An Australian Managed Investment Trust Australian tax law provides favourable tax treatment for foreign investors in Australian unit trusts that qualify to be a Managed Investment Trust (MIT). In particular, there has been a significant reduction in withholding tax on certain distributions (predominantly rental income and certain capital gains) from Australian MITs to foreign investors. Essentially, the previous non-final 30% withholding tax rate has been reduced to a final withholding tax rate of 15% from 1 July Most importantly, to be eligible for this significant reduction in the Australian withholding tax for these distributions from Australian MITs (principally managed investment schemes ), the foreign investor must be resident in a country with which Australia has an effective Exchange of Information (EOI) arrangement on taxation matters. The lower withholding tax rates apply to fund payments, ie distributions primarily of rental income and capital gains from Australian real property by Australian MITs. The lower withholding tax rates do not apply to dividend, interest and royalty income, which are subject to their own withholding tax rates. Federal GST GST is a value-added tax of 10% that replaced wholesale sales tax and a range of state taxes in It is generally payable on supplies by businesses in Australia, including supplies of goods, services, real property, rights and obligations. It is generally applied at each stage of the production and distribution chain. The sale of real estate by GST-registered businesses is generally subject to GST at the rate of 10%. However, there are a number of exceptions, including: The sale of existing (not new) residential premises is input taxed, that is, the vendor does not charge GST, but is not entitled to claim GST credits on its expenses associated with the sale The sale of property can be GST-free (ie not subject to GST - the equivalent of zero-rated in European VAT) as a going concern where it is part of the sale of the assets of an enterprise or is sold subject to lease The sale of new residential premises is taxable, however, there are special GST calculation rules 14

15 key steps for asset acquisition Seller Instruct advisors Review property information and devise strategy to deal with any issues Any restrictions/limitations on ability to sell: third party consents, banking issues (ensure early consultation) heads of terms Buyer Instruct advisors Consider sources of finance structure and time line to secure finding: debt/equity Consider relevant investment model Consider carrying out searches: whilst traditionally carried out by the buyer, the provision of searches allows the seller greater control when setting the time limit for exchange of contracts. Searches may take 3 to 8 weeks depending on the location and nature of the property Make available pre-contract legal package/ access to data site Negotiate contract Seller now committed to the deal exchange contracts Investigate title Carry out surveys, prepare reports Negotiate contract Undertake full physical Due Diligence Pay deposit Buyer now committed to the deal Seller continues to manager (in accordance with contract) Preparation of completion statement Prepare requisitions on title precontract precompletion pre-completion searches Finalise mechanics for drawdown/transfer of completion monies Discharge mortgage completion (closing) Pay completion monies Buyer assumes responsibility 15

16 savills Savills is a leading global property service provider listed on the London Stock Exchange and with over 600 offices and associates worldwide. Trusted since 1855, we have deep experience across the Asia Pacific, with over 50 offices, and in Australia we have over 800 staff focused on meeting all your property needs. Savills global network gives us a genuinely global reach, granting us access to the newest and most affluent purchasers worldwide. Savills chooses to focus on a set of clients therefore offering a premium service to organisations and individuals with whom we share a common goal. We believe our expertise, international connections and approach will be of significant benefit to your organisation. We are regarded as an innovative thinking organisation backed up with excellent negotiating skills. Despite the unprecedented economic market conditions experienced in recent years, Savills has consistently reported a strong financial performance globally. We have no debt, net cash reserves of 104m / 87m and a market cap of 572m / 480m (as at 09 March 2012). our services include Advising on property sales and investments Identifying changing market trends/insights Sourcing investment opportunities Facilitating due diligence Educating investors on new property markets and sectors Marketing strategy and targeting Real-time market intelligence Having been in the Asian market longer than most, and with over 20,000 staff in the region, Savills knows the China market inside out, with over 45% market share in the $10 million+ market. Source: Real Capital Analytics Savills is a market leading commercial and retail agent. A unique contribution of sector knowledge and entrepreneurial flair gives clients access to real estate expertise of the highest calibre. Whilst we have a revolving debt facility of 63m / 53m, we pride ourselves on the fact that we have never had to use this, despite the unparalleled global recession that we have just witnessed. 106 Offices United Kingdom & Ireland Europe Europe 57 Offices 50 Offices US, Mexico & Caribbean Americas Africa 271 Offices Middle East & Africa Asia Pacific 120 Offices Asia Pacific 16

17 australia The Australian Cross Border Investments team is led by Paul Craig and Ben Azar with responsibilities that include overseas investment into Australia across all capital cities. The team leverages off in excess of 40 quality local experts, working their local markets to provide an extensive real estate service. With over 20 years experience in the Property Industry, Paul has demonstrated a successful track record in sales of both off and on market commercial, retail and industrial sales transactions on behalf of the vendor and retained by the buyer. Since 2006 Paul has personally been involved in the sale of in excess of $3.0 billion worth of property. By travelling to Asia Pacific, Europe, the Americas and the Middle East on a regular basis, Paul and Ben are in contact with overseas investors directly and work closely with Savills Managing Directors and Savills Global Capital Transactions Heads. Our team is acknowledged across the globe as an active and known Australian Real Estate operative and is often approached for advice and representation. As part of this mandate, we undertake to directly inform all of our offices throughout Asia Pacific, Europe, the Americas and the Middle East of all opportunities. Our team has a track record with international investors and regularly travels and markets Australian stock to international funds based in: Canada China Dubai Europe Hong Kong Indonesia Japan Korea Malaysia Singapore UK USA 90% of all sales in the last 18 months sold by Savills to offshore buyers were presented to the eventual buyer in person in their home office. The Australian Cross Border Investments team will deliver an outstanding result for a number of reasons: As part of the Savills Cross Border Investments team we will ensure maximum exposure to our international database and buyers We are dedicated to the offshore investment market and travel to Asia Pacific, Europe, the Americas and the Middle East on a regular basis We are highly experienced and have an intimate knowledge of the assets we promote The strength of our systems and network of relationships that we possess The strength of our National and Global teams to work with us to ensure that all potential buyers are captured by our marketing campaign Over the past two years Savills Cross Border Investments have been involved in an excess of $700 million worth of property sales around Australia to offshore buyers. 17

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19 contact Paul Craig Managing Director Cross Border Investments Australia Level 7, 50 Bridge Street, Sydney NSW (0) (0) pcraig@savills.com.au Ben Azar Director Cross Border Investments Australia Level 7, 50 Bridge Street, Sydney NSW (0) (0) bazar@savills.com.au Tony Crabb National Head, Research Level 25, 140 William Street, Melbourne VIC (0) (0) tcrabb@savills.com.au Disclosure The information contained in this document has been compiled by Savills from various sources and includes material which may have been provided by various sources but which has not been verified or audited. This document also contains confidential material proprietary to Savills. Whilst every care has been made to ensure the information contained within is accurate, no representation is made or warranty given in respect of such information. No reliance may be placed for any purposes whatsoever on the contents of this document or its completeness. No representation or warranty, express or implied, is given and no responsibility, liability is or will be accepted by or on behalf of Savills or by any of its directors or employees or any other person as to the accuracy, completeness or correctness of the information contained in this document or any other oral information made available and any such liability is expressly disclaimed. Investment Advice: the information and opinions contained in this document do not constitute professional advice and should not be relied upon as such. Specific advice relating to individual circumstances should be obtained. 19

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