DEUTSCHE KONSUM REIT-AG - SUMMARY OF GERMAN DIVIDEND WITHHOLDING TAX IMPACT ON SOUTH AFRICAN RESIDENT SHAREHOLDERS ON THE JSE

SUMMARY OF GERMAN DIVIDEND WITHHOLDING TAX IMPACT ON SOUTH AFRICAN RESIDENT SHAREHOLDERS ON THE JSE

DEUTSCHE KONSUM REIT-AG
(Incorporated in the Federal Republic of Germany)
(Registration number HRB 13072)
FSE Share Code: A14KRD
JSE Share Code: DKR
ISIN: DE000A14KRD3
LEI: 529900QXC6TDASMCSU89
(“DKR” or “the Company”)

SUMMARY OF GERMAN DIVIDEND WITHHOLDING TAX IMPACT ON SOUTH AFRICAN
RESIDENT SHAREHOLDERS ON THE JSE

1.   INTRODUCTION

1.1.   DKR listed as a secondary listing on the main board of the JSE
       by way of an introduction on Monday, 8 March 2021, in the
       “Retail REITS” sector of the JSE (“Listing”).

1.2.   DKR has distributed a pre-listing statement regarding the
       Listing containing detailed information regarding the Company
       (“Pre-listing Statement”). The Pre-listing Statement is
       available at the Stellenbosch and Johannesburg offices of PSG
       Capital, at the addresses set out in the “Corporate Information”
       section of the Pre-listing Statement and on the Company’s
       website at https://www.deutsche-konsum.de/en/. An abridged Pre-
       listing Statement was published on SENS on 22 February 2021.

2.   SUMMARY OF GERMAN DIVIDEND WITHHOLDING TAX IMPACT ON SOUTH
     AFRICAN RESIDENT SHAREHOLDERS ON THE JSE

2.1.   In amplification of the summary of South African taxation as
       contained in the Pre-listing Statement, a summary of the impact
       of German Dividend Withholding Tax on South African Resident
       shareholders on the JSE is set out below. The summary is not a
       comprehensive description of all the tax consequences that may
       be relevant to South African Resident shareholders on the JSE.
       The summary does not constitute tax advice and is intended only
       as a guide. The summary does not deal with the specific
       circumstances of South African Resident shareholders on the
       JSE. Shareholders or potential investors should consult their
       own attorney, tax advisor or professional advisor in order to
       determine the impact of German Dividend Withholding Tax on
       their own specific circumstances.

2.2.   In   accordance  with   German   tax   laws,  DKR’s   dividend
       distributions are subject to dividend withholding tax (“German
       DWT”) at a rate of 25% plus a solidarity surcharge equal to
       5.5% of the DWT (“Surcharge”), which equates to an effective
       rate of 26.375%.

2.3.   In accordance with the double taxation agreement between German
       and South Africa (“DTA”), upon application to the German Federal
       Central Tax Office, South African resident shareholders on the
       JSE will be reimbursed 10% of the German DWT and the Surcharge
       (“German Tax Reimbursement”), reducing the effective rate to
       15%.

2.4.   Accordingly, South African resident shareholders on the JSE who
       are exempt from South African dividend withholding tax (“SA
       DWT”) will, after receiving the German Tax Reimbursement, be
       subject to an effective dividend withholding tax rate of 15%.

2.5.   South African resident shareholders on the JSE who are not
       exempt from SA DWT will after receiving the German Tax
       Reimbursement, be subject to an effective dividend withholding
       tax rate of 20%.

DKR has a primary listing on the Prime Standard on the Frankfurt
Stock Exchange and the Berlin Stock Exchange and a secondary listing
on the JSE.

8 March 2021

PSG Capital Proprietary Limited: JSE Sponsor

Date: 08-03-2021 07:10:00
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