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ARMSTRONG JONES INDUSTRIAL TRUST (AJN)

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name changed to ING Industrial Fund01/03/2001
name changed from Prime Industrial Property Trust07/01/2000
the taxation position is set out in a five page summary called the "Taxation Consequences of the Merger for Armstrong Jones Unitholders" which was contained in Section 8 of the Notice of Meeting & Explanatory Memorandum - depending on the circumstances we understand rollover relief applies but the special capital distribution of 40 cents for each reconstructed unit (which was applied to subscribe for new units which then became stapled securities in the merged group) reduced the cost base - for further details unitholders need to refer to the documentation or talk to ING Real Estate on 02 9033 103507/01/2000
we understand commencement of trading of units in the new Armstrong Jones Industrial Trust (AJN) (created from the merger of Prime Industrial Property Trust (PIP) and Armstrong Jones Industrial Fund (AJS)) was based on a unit consolidation of 1 new AJN unit for every two PIP units previously held - as part of the merger, AJS unitholders were issued 1.525 PIP units for every 1 AJS unit previously held, which were then consolidated on the basis of 1 new AJN unit for every two PIP units previously on issue - there was also a special capital distribution of 40 cents which was applied to subscribe for new units which became stapled securities in the merged group07/01/2000

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