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Dividend: tax treatment and salient dates
ATTACQ LIMITED
(Incorporated in the Republic of South Africa)
(Registration number 1997/000543/06)
JSE share code: ATT ISIN: ZAE000177218
(Approved as a REIT by the JSE)
(“Attacq” or “Company”)
DIVIDEND: TAX TREATMENT AND SALIENT DATES
Shareholders are referred to Attacq’s condensed unaudited consolidated interim financial results for the six months
ended 31 December 2019, published on SENS on 3 March 2020, wherein shareholders were advised of the final gross
dividend of 45.00000 cents per share for the six months ended 31 December 2019 (“the dividend”).
In accordance with Attacq’s status as a REIT with effect from 28 May 2018, shareholders are advised that the dividend
meets the requirements of a “qualifying distribution” for the purposes of section 25BB of the Income Tax Act, No. 58
of 1962 (“Income Tax Act”). The dividend on the shares will be deemed to be a dividend, for South African tax
purposes, in terms of section 25BB of the Income Tax Act.
Tax implications for South African resident shareholders
The dividend received by or accrued to South African tax residents must be included in the gross income of such
shareholders and will not be exempt from income tax (in terms of the exclusion to the general dividend exemption,
contained in paragraph (aa) of section 10(1)(k)(i) of the Income Tax Act) because it is a dividend distributed by a
REIT. This dividend is, however, exempt from dividend withholding tax in the hands of South African tax resident
shareholders, provided that the South African tax resident shareholders provide the following forms to their Central
Securities Depository Participant (“CSDP”) or broker, as the case may be, in respect of uncertificated shares, or the
Company, in respect of certificated shares:
a) a declaration that the dividend is exempt from dividends tax; and
b) a written undertaking to inform the CSDP, broker or the Company, as the case may be, should the
circumstances affecting the exemption change or the beneficial owner cease to be the beneficial owner,
both in the form prescribed by the Commissioner for the South African Revenue Service.
Shareholders are advised to contact their CSDP, broker or the Company, as the case may be, to arrange for the
abovementioned documents to be submitted prior to payment of the dividend, if such documents have not already been
submitted.
Tax implications for non-resident shareholders
Dividends received by non-resident shareholders will not be taxable as income and instead will be treated as an ordinary
dividend which is exempt from income tax in terms of the general dividend exemption in section 10(1)(k)(i) of the
Income Tax Act. Any distribution received by a non-resident from a REIT will be subject to dividend withholding tax
at 20.0%, unless the rate is reduced in terms of any applicable agreement for the avoidance of double taxation (“DTA”)
between South Africa and the country of residence of the shareholder. Assuming dividend withholding tax will be
withheld at a rate of 20.0%, the net dividend amount due to non-resident shareholders is 36.00000 cents per share.
A reduced dividend withholding rate in terms of the applicable DTA, may only be relied upon if the non-resident
shareholder has provided the following forms to their CSDP or broker, as the case may be, in respect of uncertificated
shares, or the Company, in respect of certificated shares:
a) a declaration that the dividend is subject to a reduced rate as a result of the application of a DTA; and
b) a written undertaking to inform their CSDP, broker or the Company, as the case may be, should the
circumstances affecting the reduced rate change or the beneficial owner cease to be the beneficial owner,
both in the form prescribed by the Commissioner for the South African Revenue Service.
Non-resident shareholders are advised to contact their CSDP, broker or the Company, as the case may be, to arrange
for the abovementioned documents to be submitted prior to payment of the dividend if such documents have not already
been submitted, if applicable.
The dividend is payable to Attacq shareholders in accordance with the timetable set out below:
2020
Last date to trade cum dividend: Tuesday, 17 March
Shares trade ex dividend: Wednesday, 18 March
Record date: Friday, 20 March
Payment date: Monday, 23 March
Notes:
1. Shares may not be dematerialised or rematerialised between Wednesday, 18 March 2020 and Friday,
20 March 2020, both days inclusive.
2. Payment of the dividend will be made to shareholders on Monday, 23 March 2020. In respect of dematerialised
shareholders, the dividend will be transferred to the Central Securities Depository Participant account or broker
account on Monday, 23 March 2020. Certificated shareholder dividend will be deposited on or about Monday,
23 March 2020.
3. Where the transfer secretaries do not have the banking details of any certificated shareholders, the cash
dividend will be held in trust by the transfer secretaries pending receipt of the relevant certificated
shareholder’s banking details whereafter the cash dividend will be paid via electronic transfer into the personal
bank accounts of certificated shareholders.
The number of shares in issue as at 31 December 2019 and as at the date of this announcement is 750 334 130 ordinary
shares of no par value which includes 46 427 553 treasury shares. Attacq’s tax reference number is 9241/038/64/6.
3 March 2020
Sponsor
Java Capital
Date: 03-03-2020 08:20:00
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