
Years ended December 31,	2023		2022
Current income tax:
Current taxes	$	8,450	$	8,079
Current taxes referring to previous periods	(1,854)		(819)
Withholding taxes and other	110		120
	$	6,706	$	7,380
Deferred income tax:
Origination and reversal of temporary differences	$	(25,660)	$	(71,195)
Impact of changes in tax rates	—		(17,330)



Withholding taxes on profits of subsidiaries	86		—
Deferred tax expense arising from the write-down, or reversal of a previous write-down, of a deferred tax asset	8,877		16,771
Other	502		709
	$	(16,195)	$	(71,045)
Income tax recovery	$	(9,489)	$	(63,665)




Years ended December 31,	2023		2022
Income before income taxes	$	129,007	$	92,157
Expected income taxes at the Canadian statutory tax rate of 26.5% (2022 - 26.5%)	$	34,187	$	24,422
Income distributed and taxable to unitholders	(51,921)		(92,252)
Net foreign rate differentials	(811)		9,145
Net change in provisions for uncertain tax positions	(548)		719
Net permanent differences	507		(6,151)
Net effect of change in tax rates	—		(17,330)
Non-recognition of deferred tax assets	8,877		16,770

Withholding taxes and other	220		1,012
Income tax recovery	$	(9,489)	$	(63,665)


As at December 31,	2023		2022
Deferred tax assets:

Loss carryforwards	$	602	$	629
Other	37		—
Deferred tax assets	$	639	$	629
Deferred tax liabilities:
Investment properties	$	540,304	$	562,578
Withholding tax on undistributed subsidiary profits	86		—
Other	(4,839)		(5,187)
Deferred tax liabilities	$	535,551	$	557,391


Years ended December 31,	2023		2022
Balance, beginning of year	$	556,762	$	600,215
Deferred tax recovery recognized in net income	(16,195)		(71,045)
Foreign currency translation of deferred tax balances	(5,655)		27,592
Net deferred tax liabilities, end of year	$	534,912	$	556,762

(e) Net cash payments of income taxes amounted to a payment of $8.3 million for the year ended December 31, 2023 (2022 — $18.1 million) which included less than $0.1 million of withholding taxes paid (2022 — less than $0.1 million).

(f) The Trust conducts operations in a number of countries with varying statutory rates of taxation. Judgment is required in the estimation of income tax expense and deferred income tax assets and liabilities in each of the Trust’s operating jurisdictions. This process involves estimating actual current tax exposure, assessing temporary differences that result from the different treatments of items for tax and accounting purposes, assessing whether it is more likely than not that deferred income tax assets will be realized and, based on all the available

evidence, determining if a provision is required on all or a portion of such deferred income tax assets. The Trust reports a liability for uncertain tax positions (‘‘unrecognized tax benefits’’) taken or expected to be taken in a tax return. The Trust recognizes interest and penalties, if any, related to unrecognized tax benefits in income tax expense.

As at December 31, 2023, the Trust had $9.8 million (2022 — $10.3 million) of unrecognized income tax benefits, (including $0.1 million (2022 — $0.2 million) related to accrued interest and penalties), all of which could ultimately reduce the Trust’s effective tax rate should these tax benefits become recognized. The Trust believes that it has adequately provided for reasonably foreseeable outcomes related to tax examinations and that any resolution will not have a material effect on the combined financial position, results of operations, or cash flows. However, the Trust cannot predict with any level of certainty the exact nature of any future possible outcome.


As at December 31,	2023		2022
Unrecognized tax benefits balance, beginning of year	$	10,279	$	10,470
Decreases for tax positions of prior years	(1,815)		(1,692)
Increases for tax positions of current year	1,244		1,452
Foreign currency impact	87		49
Unrecognized tax benefits balance, end of year	$	9,795	$	10,279

It is reasonably possible that the gross unrecognized tax benefits, as of December 31, 2023, could decrease in the next 12 months. The quantum of the decrease could range between a nominal amount and $2.2 million (2022 — a nominal amount and $2.6 million) and relates primarily to tax years becoming statute barred for purposes of future tax examinations by local taxing authorities and the outcome of current tax examinations. For the year ended December 31, 2023, a nominal amount of interest and penalties was recorded (2022 — $0.1 million) as part of the provision for income taxes in the combined statements of net income.


Major Jurisdictions
Canada			2019 through 2023
United States			2019 through 2023
Austria			2018 through 2023
Germany			2016 through 2023
Netherlands			2018 through 2023

As at December 31, 2023, the Trust has approximately $330.7 million (2022 — $285.5 million) of losses and other deductible temporary differences in various tax jurisdictions that the Trust believes are not probable to be realized. As a result, no deferred tax asset has been recognized for these losses and other deductible temporary differences as of December 31, 2023. Included in this number are Canadian capital loss carryforwards that do not expire of $140.9 million (2022 — $140.5 million).

The aggregate amount of temporary differences associated with investments in subsidiaries for which deferred tax liabilities have not been recognized as at December 31, 2023 is approximately $253.9 million (2022 — approximately $194.7 million).