the Preliminary Prospectus and the Final Prospectus;

The SMART ABS Trusts Master Trust Deed dated 11 March 2002 between the Macquarie Securitisation Management Pty Limited and Permanent Custodians Limited, the rights and obligations of which were assumed by Perpetual Trustee Company Limited pursuant to the Deed of Assumption, as amended;

The SMART ABS Trusts Master Security Trust Deed dated 27 February 2007 between Macquarie Securitisation Management Pty Limited, Perpetual Trustee Company Limited and P.T. Limited, as amended;

The SMART ABS Trusts Master Sale and Servicing Deed dated 27 February 2007 between Macquarie Securitisation Management Pty Limited, Perpetual Trustee Company Limited and Macquarie Leasing Pty Limited, as amended;

The SMART ABS Series 2015-3US Trust Trust Creation Deed dated 8 October 2015 to which Perpetual Trustee Company Limited is a party;

The SMART ABS Series 2015-3US Trust Series Supplement dated 15 October 2015 between Macquarie Securitisation Management Pty Limited, Perpetual Trustee Company Limited, Macquarie Bank Limited and Macquarie Leasing Pty Limited (the Series Supplement);

The SMART ABS Series 2015-3US Trust General Security Deed dated 14 October 2015 between Macquarie Securitisation Management Pty Limited, Perpetual Trustee Company Limited, The Bank of New York Mellon and P.T. Limited;

The SMART ABS Series 2015-3US Trust Fixed Rate Swap Agreement dated 15 October 2015 between Macquarie Bank Limited, Perpetual Trustee Company Limited and Macquarie Securitisation Management Pty Limited and the Fixed Rate Swap confirmation entered into thereunder on or about the date of this Opinion;

The SMART ABS Series 2015-3US Trust Currency Swap Agreement dated 15 October 2015 between Australia and New Zealand Banking Group Limited, Perpetual Trustee Company Limited and Macquarie Securitisation Management Pty Limited and each Currency Swap confirmation entered into thereunder on or about the date of this Opinion;

The SMART ABS Series 2015-3US Trust US$ Note Trust Deed dated 15 October 2015 between, amongst others, Macquarie Leasing Pty Limited, Macquarie Securitisation Management Pty Limited and Perpetual Trustee Company Limited;

The SMART ABS Series 2015-3US Trust Agency Agreement dated 15 October 2015 between, amongst others, Macquarie Securitisation Management Pty Limited and Perpetual Trustee Company Limited; and

The SMART ABS Series 2015-3US Trust Regulation AB Compliance Agreement dated 15 October 2015 between, amongst others, Perpetual Trustee Company Limited, Macquarie Securitisation Management Pty Limited, Macquarie Leasing Pty Limited and Macquarie Bank Limited,

which form part of the Registration Statement filed by the Depositor with the Commission under the Securities Act.

General

Our Opinion is subject to the assumptions set out in the Taxation Law Sections.

Accuracy and enforceability of Opinion Documents

Each of (a) the Tax Sharing Deed dated 19 December 2007 between, amongst others, Macquarie Group Limited (as amended by the Amending Deed (MGL Tax Sharing Deed) dated 4 February 2014), (b) the Indirect Tax Sharing Deed dated 3 September 2010 between, amongst others, Macquarie Group Limited, and (c) the Tax Funding Deed dated 19 December 2007 between, amongst others, Macquarie Group Limited (as amended by the Amending Deed (MGL Tax Funding Deed) dated 4 February 2014) remains in full force and effect, none of the terms of any of those documents have been amended, varied or waived in whole or in part, nor has any of those documents been terminated or repudiated.

The Issuer Trustee will accede to each of the documents referred to in Assumption 2.1 upon the relevant Trust being constituted.

The Opinion Documents, when entered into, (together with (a) the Deed of Assumption The SMART Trusts Master Trust Deed dated 27 February 2007 between Macquarie Securitisation Management Pty Limited and Perpetual Trustee Company Limited, and (b) the Deeds of Accession) represent and contain the entirety of the transactions entered into by the parties to the Opinion Documents in or in connection with the issue of the Notes and the provisions of the Opinion Documents have not been waived or varied in whole or in part.

No party to an Opinion Document has terminated or repudiated any term of the Opinion Documents or accepted any such termination or repudiation by another party or, in each case, purported to do so.

Restrictions on issue of Notes

The US$ Notes will only be issued in accordance with the restrictions contained in the Series Supplement, US$ Note Trust Deed and Underwriting Agreement to investors permitted under the terms of those documents (each such investor, a Relevant Investor).

General

Our Opinion is subject to the reservations, qualifications and observations set out in the Taxation Law Sections.

Current law

This Opinion is governed by and is to be construed in accordance with the Opinion Law as at the date of this Opinion. We express no opinion herein with regard to any system of law other than the Opinion Law as currently applied by the courts of the Opinion Jurisdiction. Neither do we express any opinion as to the laws of any other country or jurisdiction. None of the opinions expressed in this Opinion will be affected by the laws (including the public policy) or any relevant requirements of any jurisdiction outside the Opinion Jurisdiction.

Accuracy and enforceability of Opinion Documents

We have not been responsible for the investigation or verification of, nor do we express any view on, the accuracy or reasonableness of any facts, statements and/or assumptions contained in any of the documents listed in Schedule 1 to this Opinion nor have we attempted to determine whether any material information has been omitted therefrom.

We express no opinion as to the execution, validity or enforceability of the Opinion Documents.

Limitations of information in the Preliminary Prospectus and the Final Prospectus

Neither the Preliminary Prospectus nor the Final Prospectus contains, or purports to contain, a full description of the legal issues discussed in it and in particular the Taxation Law Sections do not summarise all possible Australian tax ramifications of the purchase, ownership and disposition of the US$ Notes. The Taxation Law Sections are at best only a summary of the provisions of relevant laws which give rise to material Australian tax consequences, from the perspective of a Relevant Investor, in the context of the purchase, ownership and disposition of the US$ Notes.

In regard to the Taxation Law Sections, there is a risk that the operation of Australian tax law as described in those sections could be successfully challenged by the Australian Taxation Office or altered by a change in law, interpretation or application (which may apply retroactively to a completed transaction).