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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 "the Company" or "the Group")
DIVIDEND: TAX TREATMENT AND SALIENT DATES
Shareholders are referred to Attacq's summarised consolidated annual financial results for the year ended
30 June 2022, published on SENS on 13 September 2022, wherein shareholders were advised of the final gross
dividend of 50.00000 cents per share for the year ended 30 June 2022 ("the dividend").
In accordance with Attacq's status as a REIT, 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
40.00000 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.
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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:
2022
Last day to trade cum dividend Tuesday, 27 September
Shares trade ex dividend Wednesday, 28 September
Record date Friday, 30 September
Payment date Monday, 3 October
Notes:
1. Shares may not be dematerialised or rematerialised between Wednesday, 28 September 2022 and Friday,
30 September 2022, both days inclusive.
2. Payment of the dividend will be made to shareholders on Monday, 3 October 2022. In respect of
dematerialised shareholders, the dividend will be transferred to the Central Securities Depository
Participant account or broker account on Monday, 3 October 2022. Certificated shareholder dividend will
be deposited on or about Monday, 3 October 2022.
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 30 June 2022 and as at the date of this announcement is 751 551 292 ordinary
shares of no par value which includes 46 427 553 treasury shares. Attacq's tax reference number is 9241/038/64/6.
13 September 2022
Sponsor
Java Capital
Date: 13-09-2022 07:06:00
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