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Notes to the Consolidated Financial Statements31 December 2024ESR Group Limited Annual Report 2024179STRATEGIC REPORTSCORPORATE GOVERNANCEFINANCIAL STATEMENTS10.INCOME TAX (CREDIT)/EXPENSE (continued)Pillar Two income taxesThe Group is within the scope of the Organisation for Economic Co-operation and Development (OECD) Pillar Two GloBE model rules. Pillar Two legislation has been enacted or substantively enacted in several jurisdictions in which the Group operates, such as Australia, effective for the financial year beginning 1 January 2024, whilst in Singapore and Hong Kong, the rules are effective for the financial year beginning 1 January 2025. Under OECD GloBE rules, the Group is liable to pay a top-up tax for the difference between its GloBE effective tax rate for each jurisdiction and the 15% minimum rate. For the financial year ended 31 December 2024, the Group has assessed and does not expect any material liability to Pillar Two top-up tax to arise based on the transitional country-bycountry safe harbour rules applying in the jurisdictions where the legislation is currently effective. The Group will continue to monitor local legislation and other developments in the relevant jurisdictions and assess the potential impact.The Group has applied the mandatory exception to recognising and disclosing information about deferred tax assets and liabilities arising from Pillar Two income taxes and will account for the Pillar Two income taxes as current tax when incurred.11.DIVIDENDSOn 21 March 2024, the Board declared a final dividend of HK$12.5 cents per ordinary share for the financial year ended 31 December 2023 (2022: final dividend of HK$12.5 cents per ordinary share for the financial year ended 31 December2022),amountingtoUS$67,375,000(2022finaldividend:US$69,886,000).ThefinaldividendofUS$67,375,000waspaidbytheCompanyduringthefinancialyearended31December2024(2022 final dividend of US$69,886,000 was paid during the financial year ended 31 December 2023).On 21 August 2024, the Board did not recommend any interim dividend for the financial year ended 31 December 2024 (2023: interim dividend of HK$12.5 cents per ordinary share for the financial year ended 31 December 2023, amountingtoUS$69,744,000whichwaspaidduringthefinancialyearended31December2023).The Board has not recommended any final dividend for the financial year ended 31 December 2024 (2023: final dividend of HK$12.5 cents per ordinary shares for the financial year ended 31 December 2023).