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Amount of special distribution to Rebosis shareholders
REBOSIS PROPERTY FUND LIMITED
(Incorporated in the Republic of South Africa)
(Registration number 2010/003468/06)
JSE share code: REB ISIN: ZAE000201687
(Approved as a REIT by the JSE)
(“Rebosis” or “the company”)
AMOUNT OF SPECIAL DISTRIBUTION TO REBOSIS SHAREHOLDERS
Rebosis shareholders are referred to the announcements released on SENS on 23 July 2015 and
30 July 2015, relating to the declaration of a special distribution to Rebosis ordinary shareholders for the
four months ended 30 June 2015 (the “Rebosis distribution” or “distribution”).
Rebosis shareholders are advised that the final amount of the Rebosis distribution per Rebosis ordinary share
for the four months ended 30 June 2015 is 38.04246 cents per Rebosis ordinary share (previously estimated
to be 38.04246 cents per Rebosis ordinary share as announced on SENS on 30 July 2015).
Tax implications
In accordance with the company’s status as a REIT, shareholders are advised that the distribution 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 distribution 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.
The distribution 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 distribution is, however, exempt from dividend withholding tax in the
hands of South African tax resident shareholders, provided that the South African resident shareholders
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 distribution 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 distribution, if such documents have not
already been submitted.
Distributions 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. It should be noted that up to 31 December 2013 distributions
received by non-residents from a REIT were not subject to dividend withholding tax. From 1 January 2014,
any distribution received by a non-resident from a REIT will be subject to dividend withholding tax at 15%,
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 shareholders. Assuming dividend
withholding tax will be withheld at a rate of 15%, the net dividend amount due to non-resident shareholders
is 32.33609 cents per share. A reduced dividend withholding rate in terms of the applicable DTA, may only
be relied on 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 distribution if such documents have
not already been submitted, if applicable.
Rebosis ordinary shares in issue at the date of declaration of this distribution: 449 934 135
Rebosis’ income tax reference number: 9170/052/18/8
13 August 2015
Corporate advisor and sponsor Legal advisor to the transaction
Java Capital Cliffe Dekker Hofmeyr
Date: 13/08/2015 09:30:00 Produced by the JSE SENS Department. The SENS service is an information dissemination service administered by the JSE Limited ('JSE').
The JSE does not, whether expressly, tacitly or implicitly, represent, warrant or in any way guarantee the truth, accuracy or completeness of
the information published on SENS. The JSE, their officers, employees and agents accept no liability for (or in respect of) any direct,
indirect, incidental or consequential loss or damage of any kind or nature, howsoever arising, from the use of SENS or the use of, or reliance on,
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