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Announcement of dividend re-investment price and confirmation of finalisation information
DIPULA INCOME FUND LIMITED
(Incorporated in the Republic of South Africa)
(Registration number 2005/013963/06)
JSE share code: DIB ISIN: ZAE000203394
(Approved as a REIT by the JSE)
("Dipula" or "the Company")
ANNOUNCEMENT OF DIVIDEND RE-INVESTMENT PRICE AND CONFIRMATION OF FINALISATION INFORMATION
Further to the declaration of a cash dividend of 25.84695 cents per share (the "cash dividend") with an election to
reinvest the cash dividend in return for new Dipula shares (the "new shares") (the "re-investment option"), announced
on SENS on Wednesday, 17 May 2023 (the "dividend election declaration"), the price per share, as determined on
Tuesday, 30 May 2023 (the "finalisation date"), applicable to Dipula shareholders electing the re-investment option
and recorded in the register on Friday, 9 June 2023 (the "record date"), is R3.52 per share (the "re-investment price").
The re-investment price represents a 3.00% discount to the 30-day volume weighted average traded price (less the cash
dividend).
The ratio in respect of the re-investment option is 7.34288 shares for every 100 shares held on the record date by South
African resident shareholders exempt from dividend tax and 5.87431 shares for every 100 shares held on the record date
by non-resident shareholders subject to dividend tax at 20%.
Where a shareholder's entitlement to the shares in relation to the re-investment option, calculated with reference to the
above share ratio, gives rise to an entitlement to a fraction of a new share, such fraction will be rounded down to the
nearest whole number with the cash balance of the dividend being retained by the shareholder.
Dividend withholding tax ("dividend tax") implications
Dividend tax implications for South African resident shareholders
Dividends received from a Real Estate Investment Trust ("REIT") are exempt from dividend tax in the hands of South
African resident shareholders provided that the shareholders have provided the requisite declaration as to residence as
detailed in paragraph 5 of the circular to Dipula shareholders dated and posted on Wednesday, 17 May 2023
(the "circular"). South African resident shareholders, who have submitted the requisite documentation and are exempt
from dividend tax, will accordingly receive a net dividend of 25.84695 cents per share.
Dividend tax implications for non-resident shareholders
Dividends received from a REIT by a non-resident shareholder will be subject to dividend tax at 20%, 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 non-resident shareholder. A reduced dividend withholding rate in terms of the applicable
DTA may only be relied upon if the non-resident shareholder has provided the requisite documentation as detailed in
paragraph 5 of the circular. Non-resident shareholders who have submitted the requisite documentation and assuming
that a dividend tax rate of 20% is applicable, will accordingly receive a net dividend of 20.67756 cents per share.
Due to the fact that the cash dividend or re-investment option may have tax implications for resident and non-resident
shareholders, shareholders are encouraged to consult their professional advisors should they be in any doubt as to the
appropriate action to take.
Illustrative example on the application of rounding and the impact of dividend tax
The application of the rounding principle of rounding down to the nearest whole number and the impact of dividend tax
on shareholders has been illustrated by way of the example below:
South African Non-resident
resident shareholders
shareholders subject to
exempt from dividend tax at
dividend tax 20%
Dividend per share (cents) 25.84695 25.84695
Dividend tax per share (cents) - 5.16939
Total net dividend per share (cents) 25.84695 20.67756
Number of shares held 100 100
Re-investment price (R) 3.52000 3.52000
Total amount available for re-investment (R) 25.84695 20.67756
Number of shares issued in terms of re-investment option 7.34288 5.87431
Total amount payable for shares acquired in terms of the re-investment option 24.64000 17.60000
(R)
Balance of distribution paid to shareholder (R) 1.20695 3.07756
Trading of Dipula shares
Shareholders are advised that, as per the published timetable, the last date to trade is Tuesday, 6 June 2023 and the shares
will trade ex-dividend on Wednesday, 7 June 2023.
As published in the dividend election declaration, shareholders electing the re-investment option are alerted to the fact
that the new shares will be listed on LDT + 3 and that these new shares can only be traded on LDT + 3 being Wednesday,
14 June 2023 due to the fact that settlement of the new shares will be three days after the record date, being Friday,
9 June 2023, which differs from the conventional one day after record date settlement process.
Shareholders are reminded that the last day to elect to receive the re-investment option is 12:00 (South African time) on
Friday, 9 June 2023. No action is required if you wish to receive the cash dividend.
The salient dates, timetable and all other information relating to the cash dividend (including the tax implications) and
re-investment option disclosed in the declaration announcement remain unchanged.
30 May 2023
Sponsor
Java Capital
Date: 30-05-2023 11:23:00
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