Wrap Text
Final distribution
Irongate Group (JSE: IAP)
Comprising Irongate Property Fund I (IPF I, ARSN 162 067 736) and Irongate Property Fund II (IPF II, ARSN 644 081 309), established in Australia
and registered with ASIC as managed investment schemes
Operated by Irongate Funds Management Limited (ACN 071 514 246; AFSL 290 909) (Responsible Entity)
IPF I is registered as a foreign collective investment scheme in terms of the Collective Investment Schemes Control Act No.45 of 2002
ISIN: AU0000046005
(IAP or the Fund)
Final distribution
Notice is hereby given of a final distribution for the six months ended 31 March 2022,
declaration number 18, of:
- 4.67000 AUD cents per stapled security pre withholding tax (WHT)
- 4.26439 AUD cents per stapled security post WHT
Tax of 0.40561 AUD cents per stapled security (being 8.68538% per stapled security) will be
withheld from the final distribution paid to non-Australian securityholders holding stapled
securities on the Fund’s South African sub register. Amounts will also be withheld from non-
Australian securityholders holding stapled securities on the Fund’s Australian sub register.
The salient events and dates relating to the final distribution are as follows (all times and dates
are Johannesburg time, unless otherwise indicated):
Event 2022
Declaration date Tuesday, 10 May
Cross border movement of stapled securities between the Friday, 20 May
Fund’s South African sub register and the Fund’s
Australian sub register ceases at the close of business in
South Africa or Australia (as applicable)
Announce AUD into ZAR currency conversion rate(1) for Monday, 23 May
payment of the final distribution to securityholders on the
Fund’s South African sub register, by 11h00
Last day to trade cum distribution on the JSE(2) Tuesday, 24 May
Stapled securities trade ex-distribution on the JSE Wednesday, 25 May
Last day to trade cum distribution on the ASX Wednesday, 25 May
(Sydney time)
Stapled securities trade ex-distribution on the ASX Thursday, 26 May
(Sydney time)
Record date Friday, 27 May
Cross border movements of stapled securities between Monday, 30 May
the Fund’s South African sub register and the Fund’s
Australian sub register recommences
Payment of final distribution Friday, 10 June
1. Exchange rate calculated on Monday, 23 May 2022 (for release on SENS by 11h00).
2. Stapled securities may not be dematerialised or rematerialised between commencement of trade on the JSE on
Wednesday, 25 May 2022 and close of trade on Friday, 17 May 2022, both dates inclusive.
Fund payment amount applicable to the final distribution for the six
months ended 31 March 2022
This information is only applicable to foreign securityholders and other entities that are obliged
to withhold tax on payments made to foreign residents. Australian-based securityholders should
rely on tax statements that are due to be mailed by Thursday, 30 June 2022. For
completeness, tax will be deducted from payments made to an Australian resident where the
Australian securityholder does not provide an Australian business number or tax file number.
The final distribution includes a fund payment amount of 0.40561 AUD cents per stapled
security. The fund payment has been determined in accordance with Subdivision 12A-B of
Schedule 1 to the Taxation Administration Act 1953, being the amount from which an amount
would have been required to be withheld under Subdivision 12-H of Schedule 1 to the Taxation
Administration Act 1953 if the payment had been made to an entity covered by section 12-410
of Schedule 1 to the Taxation Administration Act 1953. The fund payment relates to the six
months ended 31 March 2022.
The Fund declares that IPF I is an Attribution Managed Investment Trust for the purposes of
Subdivision 12-H of Schedule 1 of the Taxation Administration Act 1953 in respect of the
income year ended 31 March 2022.
Distribution information for the half year ended 31 March 2022
This information is only applicable to foreign securityholders and other entities that are obliged
to withhold tax on payments made to foreign residents. The final distribution is being made from
IPF I. There is no distribution component from IPF II.
Breakdown of the Total cash Component Component New
distribution components distribution subject to subject to Zealand
for the half year ended 31 fund other non- sourced
March 2022(3) payment resident Income
withholding withholding
Net rental income 1.65420 1.65420 - -
Capital gain 0.99867 0.99867
Total fund payment (incl 2.65287 2.65287 - -
capital gains)
Interest income 0.07676 - 0.07676 -
Foreign income(4) 0.46779 - - 0.46779
Non-assessable amount 1.47258 - - -
Total distribution 4.67000 2.65287 0.07676 0.46779
Foreign tax paid - - - 0.02780
3. All amounts shown as AUD cents per stapled security.
4. The foreign income component of the distribution is subject to New Zealand corporate tax.
Distribution information for the year ended 31 March 2022
This information is only applicable to foreign securityholders and other entities that are obliged
to withhold tax on payments made to foreign residents.
Breakdown of the Total cash Component Component New
distribution components distribution subject to subject to Zealand
for the half year ended 31 fund other non- sourced
March 2022(5) payment resident Income
withholding withholding
Net rental income 4.41741 4.41741 - -
Capital gains 0.99867 0.99867 - -
Total fund payment (incl 5.41608 5.41608 - -
capital gains)
Interest income 0.19179 - 0.19179 -
Foreign income(6) 0.89568 - - 0.89568
Non-assessable amount 2.69505 - - -
Total distribution 9.19860 5.41608 0.19179 0.89568
Foreign tax paid - - - 0.02780
5. All amounts shown as AUD cents per stapled security.
6. The foreign income component of the distribution is subject to New Zealand corporate tax.
General securityholder tax information for securityholders holding stapled
securities on the Fund’s South African sub register
IPF I and its management arrangements are structured to meet the required criteria to be
classified as an Attribution Managed Investment Trust for Australian tax purposes. As an
Attribution Managed Investment Trust, the Responsible Entity will be required to withhold tax on
Australian sourced income at a concessional rate of 15% on fund payments (or 10% for certain
fund payments from a Clean Building MIT) to individual and institutional securityholders in South
Africa and certain other jurisdictions with an exchange of information (EOI) agreement with
Australia. Distributions of Australian sourced income to securityholders that are not resident in
EOI jurisdictions will be subject to WHT at the rate of 30%.
The New Zealand sourced income is subject to the corporate tax rate in New Zealand of 28% and
is not subject to Australian WHT.
The proportion of the payment in respect of the six months ended 31 March 2022 which is
attributable to a fund payment from a Clean Building MIT is nil AUD cents per stapled security.
The effect of these taxes on the final distribution has been to reduce the rate of WHT to 8.68538%,
equivalent to 0.40561 AUD cents per stapled security, through certain deductions such as
depreciation. Thus, tax of 0.40561 AUD cents per stapled security will be withheld from the final
distribution accruing to securityholders and will be paid to the Australian Taxation Office for
Australian sourced income.
South African securityholder South African income tax implications
The implications below are of a general nature and should not be relied upon by securityholders
as specific South African income tax advice. It does not purport to be a complete analysis of the
potential South African income tax consequences applicable to each securityholder in respect of
distributions received/accrued from the Fund. Securityholders should obtain independent
income tax advice with regard to the South African income tax consequences of acquiring,
holding and disposing of stapled securities having regard to each securityholder’s
circumstances.
The final distribution is regarded as a distribution from a foreign trust for South African
securityholders and will be taxed on a flow-through basis as IPF I is a registered Collective
Investment Scheme.
The final distribution should comprise taxable income and is to be taxed as such dependent on
the underlying nature of the income and capital gains noted above, in the hands of South African
securityholders. The pre-WHT distribution is to be included in a securityholder’s taxable income
and subject to normal tax in full. Tax paying securityholders may be entitled to claim a foreign tax
credit equivalent to 8.68538%. For distributions where the South African securityholder only
becomes entitled to the distribution in a financial year subsequent to the financial year in which
the income or capital gain was earned by the Fund, the South African securityholder may not be
able to claim a foreign tax credit.
10 May 2022
Johannesburg
Sponsor
Investec Bank Limited
Date: 10-05-2022 09:26:00
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