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SBK - Standard Bank Group Limited - Tax Implications - Interim distribution on

Release Date: 14/09/2007 14:37
Code(s): SBK
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SBK - Standard Bank Group Limited - Tax Implications - Interim distribution on ordinary shares Standard Bank Group Limited (Incorporated in the Republic of South Africa) (Registration number 1969/017128/06) South African Share Code: SBK Namibian Share Code: SNB ISIN: ZAE000057378 Tax implications - Interim Distribution on Ordinary Shares Background The 2007 interim distribution in respect of Standard Bank Group Limited`s ordinary shares, payable on 17 September 2007, amounts to 181 cents per share. This distribution partially comprises a return of share premium, and partially comprises a distribution of reserves. There are different tax implications relating to these two aspects. This note discusses these tax implications. Queries can be referred to: Kim Howard, Director, Investor Relations, +27 11 636 7811 South African tax implications The 2007 interim distribution in respect of Standard Bank Group Limited`s ordinary shares, payable on 17 September 2007, amounts to 181 cents per share. This amount has the following components: (a) Distribution from pure share premium 24c (b) Distribution from share premium sourced from past reserves 76c (c) Distribution from distributable reserves 81c The effects of South African tax law are as follows: (a) Distribution from pure share premium: This portion is treated as a return of capital. It is not treated as a dividend. In consequence, it is not subject to Secondary Tax on Companies ("STC") on distribution, and does not qualify as an STC credit in the hands of the recipient, where that recipient is subject to STC. It is a taxable receipt for the purposes of Income Tax or Capital Gains Tax ("CGT") - it depends on the recipient`s tax status as to which of these two forms of tax applies. Under the roll-over provisions of the Income Tax Act (8th Schedule, para 76(b)), this taxable receipt only needs to be taken into account for tax purposes when the underlying shares are disposed of. (b) Distribution from share premium sourced from past reserves: This portion is not treated as a return of capital. It is treated as a dividend. In consequence, it is subject to STC on distribution, and does qualify as an STC credit in the hands of the recipient, where that recipient is subject to STC. (c) Distribution from distributable reserves: The position is identical to (b). Tax implications in other countries We cannot advise on the effects of tax law in other countries, and strongly recommend that professional advice be obtained in those countries. Sponsor Standard Bank Date: 14/09/2007 14:37:01 Supplied by www.sharenet.co.za 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, information disseminated through SENS.

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