„ZAIN PROPERTY DEVELOPMENT“ D.O.O.

PODGORICA

MEETING MINUTES

Date: 13.06.2019
Location: BENCOM LTD,
Podgorica

Dear Sirs,

Following the meeting that was held in Bencom offices in Podgorica on 13th June and an
agreement that was reached, we would like to give in writing explanations related to tax aspect of
your future real estate sales, and other matters that were discussed on meeting.

1. In Montenegro, sales of newly built properties are subject to value added tax, according to
the Law of value added tax. For each sale of property based on Sales agreement, it is
needed to make sales calculation in which the tax calculation will be declared.
Following the mentioned montenegrin Law, sales calculation (as well as invoice) should
contain selling price of real estate divided on the value(part) that is not subject to value
added tax and the value (part) of price that is subject to value added tax(general tax rate).
The Law defines that values of payed land and utilities(bulding permit) are not subject to
value added tax, VAT-free turnover. VAT-free part per square meter will be calculated
based on building permit that states allowed number of square meters, and that part will
be used in sales calculation as parameter.

Example: Land and utilities are paid in the amount of 1.000.000 €. It is allowed to build
property with the total size of 2.500 m².

Calculation of VAT-free part per square meter = 1.000.000 € / 2.500 m² = 400€/m²

Selling value of 500 m² Villa is 800.000 €.

Selling calculation with tax calculation would look like this:

CALCULATION BASED ON PROPERTY SALE AGREEMENT

Customer: XX

Nr. Description m2 Amount

1. Price of land and utilities per m² 400,00 €
2. Total real estate property available for sale 2.500 m2
3. Total size of sold property (Villa) 500,00 m2
4. Total value of villa according to sale agreement 800.000,00 €

»BENCOM« d.o.o. Herceg-Novi

Prizrenska 19, 85347 Igalo, Crna Gora
Tel: +382 31 331 860; Fax: +382 31 331 950
PIB: 02199653; PDV: 90/31-00212-2
Web: www.bencomltd.com E-mail: office@bencomltd.com
5. Total value that is VAT-free

For land and utilities (1 x 3) 200.000,00 200.000,00 €

6. Base for calculating VAT - taxable part ( 4.-5.) (800.000 600.000,00 €

€ - 200.000 € = 600.000 €)

7. Calculated VAT( 21% ) from taxable part (6.) is obtained

by applying recalculated rate of 17,355% (600.000,00 € 104.130,00 €
x 17,355%)

Note: When calculating the VAT liability, the tax that investor paid to suppliers for construction
and other business services is recognized tax. Paid tax prepayment is recorded as tax credit, and it
reduces the payment obligation for VAT.

2. We stated on meeting that owners (individuals) and engineer who will come to
Montenegro from time to time will sign Service contract in order to receive reimbursement
of expenses. Service contracts will state the fee for their consulting services and similar
services. Tax on their fee will be calcualted upon payment, in the amount of 9% their gross
income base.

Also was determined that contracts will define accommodation in the hotel and plane
tickets expenses to go to burden of the „Zaina“ Montenegro. On these expenses there will
be no tax of 9%. These expenses will lower base for Profit tax, on the end of year.

3. It was agreed on meeting to give Bencom the list of services that would agency perform for
the client. Based on that list offer with financial compensation will be delivered.

In Podgorica, 13.06.2019.

»BENCOM« d.o.o. Herceg-Novi

Prizrenska 19, 85347 Igalo, Crna Gora
Tel: +382 31 331 860; Fax: +382 31 331 950
PIB: 02199653; PDV: 90/31-00212-2
Web: www.bencomltd.com E-mail: office@bencomltd.com