Make The World
More Sustainable[Provisional Translation Only]
This English translation of the original Japanese document is provided solely for information purposes.
Should there be any discrepancies between this translation and the Japanese original, the latter shall prevail.

September 20, 2023
Ichigo Green Infrastructure Investment Corporation(“Ichigo Green,” 9282)
Japanese Tax Treatment of FY23/6 Dividend
Dear Shareholders,
Deepest thanks for your investment with Ichigo Green. We are honored to work for you.
Ichigo Green resolved at its August 10, 2023 board meeting that, in addition to a
dividend of JPY 1,874 per share for FY23/6, it will pay a Dividend in Excess ofEarnings (“DEE”) of JPY 2,221 per share. The dividend and DEE (together, the “totaldividend”) will be paid on September 21, 2023. The DEE is being paid from Ichigo
Green’s solar power production revenues (which Ichigo Green receives in cash) that are
not treated as income under Japanese tax, because they are offset by non-cash
depreciation expenses.
This notice outlines the DEE’s tax treatment under Japanese tax law. Not being sourcedfrom Ichigo Green’s net income, the DEE is treated as a return of capital and therefore
differs from the dividend, which is treated as a distribution of retained earnings. As areturn of capital, the DEE is treated as a “deemed sale” of Ichigo Green shares byshareholders that generally generate capital gains/losses.
While this notice seeks to describe the payment and tax treatment of the dividend andDEE pursuant to Japanese tax, it has been prepared for informational purposes only anddoes not constitute tax, accounting, or legal advice. Because it addresses domestic
Japanese tax treatments, it does not provide information on the tax issues of non-Japan
domiciled investors. Actual tax treatment may vary considerably depending uponshareholders’ tax domiciles. In addition, as described below, the calculation ofacquisition prices to determine one’s tax basis, capital gains/losses from deemed sales,
and taxes on future share sales will differ depending upon shareholders’ specificcircumstances. Please consult with your tax, accounting, or legal advisors to determine
appropriate treatment for your specific circumstances.
1. FY23/6 Dividend Payment
Ichigo Green’s FY23/6 total dividend will be paid from retained earnings (dividend ofJPY 1,874 per share) and paid-in capital (DEE of JPY 2,221 per share). As different
payment procedures are necessary for the two kinds of dividends, the following
Japanese tax documents (Japanese only) will be provided to shareholders according to
the specified method of payment for each shareholder.
(1) For shareholders who have chosen to receive dividends via bank transfer:“Statement of Dividends” and “Bank Transfer Notice” or“Statement of Dividends” and “Procedures for Receiving Dividends”(2) For shareholders who have not chosen to receive dividends via bank transfer:“Statement of Dividends” and “Receipt for Dividends”
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2. Japanese Tax Treatment of FY23/6 DEE(1) Income Categorization (Articles 24 and 25, Income Tax Act)a. Under Japanese tax law, a payment made from paid-in capital is considered a returnof capital while a payment made from funds other than paid-in capital is considered adeemed dividend. Because the DEE for FY23/6 is paid entirely from paid-in capital,
it is not a deemed dividend.
b. A return of capital is treated as a deemed sale under Japanese tax, because it isconsidered a partial sale of shares by shareholders. A deemed sale requires that theshare acquisition price be adjusted (decreased) and that gains/losses from the deemedsale be calculated.
c. In cases where payment of the DEE results in a capital gain, shareholders usuallymust file an income tax return. However, some securities companies withhold taxes
for certain types of securities accounts, and in such case, shareholders may not berequired to file an income tax return. For details, please consult with your securities
company.
Dividend Overview
Total Dividendper Share

Source of Funds

Type of Dividend

Japanese Tax Treatment

RetainedEarnings(JPY 1,874)

Dividend(JPY 1,874)

Distribution from Retained Earnings
・Regular tax withholding at source
Return of Capital
・Not subject to tax withholding atsource
・Considered deemed salegenerating capital gain/loss

JPY 4,095
Paid-in Capital(JPY 2,221)

DEE(JPY 2,221)(2) Capital Gain/Loss from a Deemed Sale (Article 37-11, Act on Special Measures
Concerning Taxation)
a. A capital gain/loss from a deemed sale arises because pursuant to Japanese tax a
return of capital is considered a partial sale of shares by shareholders.
b. In the diagram below, (c) capital gain/loss is equal to (a) deemed income minus(b) acquisition price of shares deemed to have been sold.
c. For the FY23/6 DEE, there is no deemed dividend, and the percentage of paid-in
capital deemed returned is 6.2%.

=DEE per share *Number of shares held(b) Acquisition price ofshares deemed sold(c) Capital gain/loss fromdeemed sale(a) – (b)(a) Deemed income–Deemed dividend (JPY 0)=Previous totalacquisition price ofshares*Percentage of paid-in
capital deemed returned(6.2%)=(a) Deemed income–(b) Acquisition price ofshares deemed sold2

Sample Calculation of Capital Gain/Loss from Deemed Sale:
10 Ichigo Green shares acquired at JPY 70,000 per share during FY23/6(a) Deemed income= JPY 2,221 (DEE) * 10 shares – JPY 0 (zero deemed dividend) = JPY 22,210(b) Acquisition price of shares deemed sold= (JPY 70,000 * 10 shares) * 6.2% (percentage of paid-in capital deemed returned)= JPY 43,400(c) Capital gain/loss from deemed sale = JPY 22,210 – JPY 43,400 = – JPY 21,190
Please note that a capital gain on the FY23/6 DEE is only expected for shareholders
with an average acquisition price less than JPY 35,823. (This calculation could change
if a shareholder further acquires or sells shares between the ex-dividend date (June 29,2023) and the day on which the dividend payment is received.)
If the calculation in (c) above results in a negative value, there will be a deemed losson the sale.
For details regarding the calculation of gains/losses from a deemed sale, please
consult with your local tax office or tax advisor.
(3) Calculation of Acquisition Price (Tax Basis) (Article 114, Clause 1, Order for
Enforcement of the Income Tax Act)a. Under Japan’s tax law, the acquisition price (tax basis) of each share will be adjusted.
b. The new acquisition price is calculated as shown below. The percentage of paid-in
capital deemed returned is 6.2%.
Newacquisition
price pershare=Previousacquisition
price pershare

Previousacquisition
price pershare–*Percentage ofpaid-in capital
deemed returned(6.2%)

Sample Calculation of Acquisition Price (Tax Basis):
10 Ichigo Green shares acquired at JPY 70,000 per share during FY23/6(a) Tax basis adjustment per share (previous acquisition price * percentage of paid-in
capital deemed returned)= JPY 70,000 * 6.2% (percentage of paid-in capital deemed returned)= JPY 4,340(b) New acquisition price (tax basis) per share = JPY 70,000 – JPY 4,340 = JPY 65,660(c) Total new acquisition price (tax basis) = JPY 65,660 * 10 shares = JPY 656,600
For shareholders who have “Tokutei” securities accounts, adjustments to acquisition
price are typically handled by the securities company. For details, please consult withyour securities company.

3(4) Information for Individual Shareholders
Items prescribed in Article 114, Clause 5,
Order for Enforcement of the Income Tax Act Notification
Percentage of paid-in capital deemed returned (Article 61,
Clause 2, Item 5, Order for Enforcement of the Income Tax Act
concerning return of capital)

6.2%(5) Information for Corporate Shareholders
Items prescribed in Article 23, Clause 4,
Order for Enforcement of the Corporation Tax Act Notification
Items stipulated in Article 24, Clause 1, Corporation Tax Act
which caused the delivery of money or other assets
Date when return of capital takes place
Outstanding shares as of the record date of return of capital
Deemed dividend per share
Items prescribed in Article 119-9, Clause 2,
Order for Enforcement of the Corporation Tax Act Notification
Percentage of paid-in capital deemed returned (Article 23,
Clause 1, Item 5, Order for Enforcement of the Corporation Tax
Act concerning return of capital)
Decrease in capital surplus due to return of capital

Return of capital
September 21, 2023
102,966 shares– (JPY 0)

6.2%
JPY 228,687,486

3. Other Japanese Tax Reference Information(1) Upon receiving payment of the DEE, shareholders must follow the below
procedures that differ from procedures pertaining to ordinary dividends paid fromretained earnings:
a. Shareholders will need to calculate capital gains/losses from a deemed sale. In
general, taxation of capital gains/losses from a deemed sale is not calculated within“Tokutei” securities accounts. However, certain types of securities accounts may offer
this calculation, so shareholders should confirm details with their securities company.
b. If there is a capital gain from a deemed sale, an income tax return must be filed. It is
expected that a capital gain pertaining to the FY23/6 DEE (JPY 2,221 per share) will
only occur if a shareholder’s average acquisition price is less than JPY 35,823.
Certain securities accounts may withhold taxes on this capital gain, and in such case ashareholder may not need to file an income tax return. Shareholders should confirm
details with their securities company.
c. If a shareholder has a capital loss on a deemed sale and wishes to offset the loss
against capital gains on other listed securities or wishes to carry forward such loss,
then the shareholder must file an income tax return. Netting and carry forward ofcapital losses on a deemed sale may be automatically processed for shareholders with
“Tokutei” securities accounts, and in such case the filing of an income tax return may
not be necessary. Shareholders should confirm details with their securities company.
d. Acquisition prices must be adjusted. Shareholders should confirm details with theirsecurities company.
e. For individual shareholders who hold Ichigo Green shares in a tax-exempt NISA orJunior NISA account, capital gains from a deemed sale are subject to tax-exempt
status while capital losses are also ignored. Shareholders should confirm details with
their securities company.
4(2) Important Additional Information
This notice outlines the tax treatment of the FY23/6 DEE and required shareholder
notifications pursuant to Japanese tax. Because the specific tax treatment can vary forshareholders depending on their specific circumstances, the information outlined in thismaterial is not at all exhaustive and should not be solely relied upon. Shareholders
should direct any inquiries to the indicated parties in section 4 below.
Shareholders are advised to keep this notice, as it can serve as evidence for calculationof the share acquisition price (tax basis) for any future Ichigo Green share sales. This
notice is also posted on Ichigo Green’s website (www.ichigo-green.co.jp/en).
4. Inquiries(1) For general inquiries, please contact the Shareholder Registrar:
Mizuho Trust & Banking Co., Ltd.
Securities Agency Division
Telephone (Toll-free from Japan): 0120-288-324 (Japanese only)(From overseas): 042-679-6607 (Japanese only)
Available on weekdays from 9 a.m. to 5 p.m. JST(2) For specific inquiries concerning adjustments of acquisition prices (tax basis), please
consult with your securities company, local tax office, or tax advisor.
(3) For inquiries concerning filing an income tax return, please consult with your local
tax office or tax advisor.

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