Brookfield Renewable Corp

Considerations Relating to Section 367(a) of the Code

In general, for a transfer of property by a U.S. person to a non-U.S. corporation to qualify for the nonrecognition of gain under certain provisions of the Code, certain additional requirements under Section 367(a) of the Code and the Treasury Regulations thereunder may apply. In determining whether these additional requirements apply to the Transaction, a U.S. Holder that exchanges BEP units for BEP Inc. Class A Shares pursuant to the Unit Exchange will be deemed to transfer to BEP Inc. a proportionate share of the assets of BEP, BRELP, and the Fiscally Transparent Subsidiaries. Such assets include, without limitation, the holder’s proportionate share of (i) equity interests in certain non-U.S. holding companies and other non-U.S. entities classified as corporations for U.S. federal income tax purposes (“Non-U.S. Equity Interests”); (ii) equity interests in certain U.S. holding companies and other U.S. entities classified as corporations for U.S. federal income tax purposes (“U.S. Equity Interests”); and (iii) loans made by BRELP or other Fiscally Transparent Subsidiaries to lower-tier entities (“Holdco Debt Obligations”).

With respect to the deemed transfer of Non-U.S. Equity Interests, additional special rules may apply to a U.S. Holder that, immediately after the Unit Exchange, actually or constructively owns 5% or more, by vote or value, of the issued and outstanding stock of BEP Inc. within the meaning of Treasury Regulation Section 1.367(a)-3(b)(1)(i). These additional special rules will also apply to any U.S. Holder that exchanges BEPC exchangeable shares for BEP Inc. Class A Shares pursuant to the Share Exchange and, immediately after the Share Exchange, actually or constructively owns 5% or more of the stock of BEP Inc., as described in the preceding sentence. With respect to the deemed transfer of U.S. Equity Interests, additional special rules may apply to a U.S. Holder that, immediately after the Unit Exchange, actually or constructively owns 5% or more, by vote or value, of the issued and outstanding stock of BEP Inc. within the meaning of Treasury Regulation Section 1.367(a)-3(c)(5)(ii).

This summary does not address the special rules that may apply to a U.S. Holder, whether of BEP units or BEPC exchangeable shares, that is treated for U.S. federal income tax purposes as actually or constructively owning 5% or more, by vote or value, of the issued and outstanding stock of BEP Inc. (a “5% BEP Inc. Shareholder”), as described in the preceding paragraph. Such U.S. Holders are urged to consult their tax advisors regarding the U.S. federal income tax consequences of the Unit Exchange or the Share Exchange, as applicable, with regard to their particular circumstances.

General

Except as otherwise noted, and subject to the limitations, assumptions, and qualifications described above under “Certain United States Federal Income Tax Considerations” and herein, the legal conclusions set forth below under the headings “Consequences to U.S. Holders” and “Consequences to Non-U.S. Holders” as to certain material U.S. federal income tax consequences to U.S. Holders and Non-U.S. Holders relating to the Transaction and the ownership and disposition of BEP Inc. Class A Shares received pursuant to the Transaction constitute the opinion of Torys LLP, counsel to BEP, BEPC, and BEP Inc. This opinion is based upon and subject to certain assumptions, qualifications, limitations, and representations from BEP Inc., BEPC, BN, the BEP General Partner, and BREPH, as well as certain covenants and undertakings by the foregoing entities. Among other things, this opinion assumes the absence of relevant changes in fact or law between the date of this Circular and the Effective Date. If any of the assumptions, qualifications, limitations, representations, covenants, or undertakings is incorrect, incomplete, or inaccurate, or is violated, then the validity of this opinion may be affected, and the U.S. federal income tax consequences could differ, perhaps substantially, from those described in this Circular. An opinion of counsel represents counsel’s best legal judgment, but it does not bind the IRS or any court. Accordingly, notwithstanding this opinion, there can be no

assurance that the IRS will not assert a position contrary to one or more of the conclusions set forth herein or that a court would not sustain such a challenge, in which case the U.S. federal income tax consequences to holders of BEP units or BEPC exchangeable shares could differ materially and adversely from the U.S. federal income tax consequences described below.