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MVL - Mvelaphanda Resources Limited - SA Tax Considerations regarding the distribution of Gold Fields shares Mvelaphanda Resources Limited (Incorporated in the Republic of South Africa) (Registration number: 1980/001395/06) Share Code: MVL ISIN: ZAE000050266 ("Mvela Resources") SOUTH AFRICAN TAX CONSIDERATIONS REGARDING THE DISTRIBUTION BY MVELA RESOURCES OF 22 218 000 ORDINARY SHARES IN THE CAPITAL OF GOLD FIELDS LIMITED ("Gold Fields shares") TO HOLDERS OF ORDINARY SHARES IN ITS CAPITAL ("Mvela Resources ordinary shareholders") Allocation of the tax cost of the ordinary shares in the capital of Mvela Resources ("Mvela Resources ordinary shares") on the distribution of the Gold Fields shares The purpose of this announcement is to advise Mvela Resources ordinary shareholders of the closing prices of the Gold Fields shares and the Mvela Resources ordinary shares on 28 January 2011, and of the ratio in which the expenditure incurred in connection with the acquisition of the Mvela Resources ordinary shares, or their valuation date values, as the case may be, must be allocated to the Gold Fields shares and the Mvela Resources ordinary shares (the "allocation ratio"). The distribution of the Gold Fields shares by Mvela Resources on 31 January 2011 was a capital distribution under paragraph 76 of the Eighth Schedule of the Income Tax Act, No. 58 of 1962, as amended (but outside of the section 46 unbundling provisions). This requires each Mvela Resources ordinary shareholder to treat the distribution as a "part" disposal of their Mvela Resources ordinary shares in terms of paragraph 76A of the Eighth Schedule. The "proceeds" of the part disposal is regarded as being the market value of the Gold Fields shares distributed to the Mvelaphanda Resources ordinary shareholders. To calculate the "base cost" of the part of the Mvela Resources ordinary shares deemed to have been disposed of, the Mvela Resources ordinary shareholders must allocate part of the expenditure incurred in connection with the acquisition of the Mvela Resources ordinary shares and/or the valuation date value of the Mvela Resources ordinary shares, as the case may be, to the Gold Fields shares and the Mvela Resources ordinary shares, pro rata, based on their relative market values at the close of business on the last business day prior to the distribution. Mvela Resources shareholders are advised that the allocation ratio, based on the relative market values of the Gold Fields shares and the Mvela Resources ordinary shares at the close of business on 28 January 2011, was as follows: Closing price Market value Ratio 28/01/2011 R R % Gold Fields 111.82 2 484 416 760 24.91% shares distributed Mvela 37.09 8 081 209 999 75.09% Resources ordinary shares Total 100% Johannesburg Date: 2 February 2011 Financial adviser and sponsor to Mvela Resources J.P. Morgan Attorneys and tax advisers to Mvela Resources Bowman Gilfillan Independent reporting accountants PricewaterhouseCoopers Inc. Date: 02/02/2011 17:29:01 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.
