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Declaration of cash distribution with the election to reinvest cash distribution in return for Vukile linked units
VUKILE PROPERTY FUND LIMITED
(Incorporated in the Republic of South Africa)
(Registration number 2002/027194/06)
JSE share code: VKE NSX share code: VKN
ISIN: ZAE000056370
(Granted REIT status with the JSE)
(“Vukile” or “the company”)
DECLARATION OF A NORMALISED INTERIM CASH DISTRIBUTION WITH THE ELECTION TO
REINVEST THE CASH DISTRIBUTION IN RETURN FOR VUKILE LINKED UNITS
Linked unitholders are advised that the board of directors of Vukile has declared a normalised interim cash
distribution of 54.81000 cents per linked unit out of distributable income for the six-month period ended 30 September
2013 (the “cash distribution”).
Linked unitholders will be entitled, in respect of all or part of their linked unitholding, to elect to re-invest the cash
distribution in return for Vukile linked units (the “linked unit reinvestment alternative”), failing which they will
receive the cash distribution of 54.81000 cents per linked unit that will be paid to those linked unitholders not electing
to participate in the linked unit reinvestment alternative.
A circular providing further information in respect of the cash distribution and linked unit reinvestment alternative
will be posted to Vukile linked unitholders on 22 November 2013.
Linked unitholders who have dematerialised their linked units through a Central Securities Depository Participant
(“CSDP”) or broker should instruct their CSDP or broker with regard to their election in terms of the custody
agreement entered into between them and their CSDP or broker.
Linked unitholders are advised that interim results for the six-month period ended 30 September 2013 will be released
on SENS on 25 November 2013.
Salient dates and times
The salient dates and times for the cash distribution and linked unit reinvestment alternative are as set out below.
2013
Circular and form of election posted to linked unitholders Friday, 22 November
Finalisation information including the linked unit ratio and price per linked unit
published on SENS Friday, 29 November
Last day to trade in order to participate in the election to receive the linked unit
reinvestment alternative or to receive a cash distribution Friday, 6 December
Linked units to trade ex-distribution Monday, 9 December
Listing of maximum possible number of linked units under the linked unit reinvestment
alternative Tuesday, 10 December
Last day to elect to receive the linked unit reinvestment alternative or to receive a cash
distribution (no late forms of election will be accepted) at 12:00 (SA time) Friday, 13 December
Record date for the election to receive the linked unit reinvestment alternative or to
receive a cash distribution Friday, 13 December
Cash distribution cheques posted to certificated linked unitholders on or about Tuesday, 17 December
Accounts credited by CSDP or broker to dematerialised linked unitholders with the cash
distribution payment Tuesday, 17 December
Linked unit certificates posted to certificated unitholders on or about Wednesday, 18 December
Accounts updated with the new linked units (if applicable) by CSDP or broker to
dematerialised linked unitholders Wednesday, 18 December
Announcement of results of cash distribution and linked unit reinvestment alternative in
the press Wednesday, 18 December
Adjustment to linked units listed on or about Thursday, 19 December
Notes:
1. Linked unitholders electing the linked unit reinvestment alternative are alerted to the fact that the new
linked units will be listed on LDT + 2 and that these new linked units can only be traded on LDT + 2, due to
the fact that settlement of the linked units will be two days after the record date, which differs from the
conventional one day after record date settlement process.
2. Linked units may not be dematerialised or rematerialised between Monday, 9 December 2013 and Friday,
13 December 2013, both days inclusive.
3. The above dates and times are subject to change. Any changes will be released on SENS and if required, published
in the press.
Tax implications
Vukile was granted REIT status by the JSE Limited with effect from 1 April 2013 in line with the REIT structure as
provided for in the Income Tax Act, No. 58 of 1962, as amended (the “Income Tax Act”) and section 13 of the JSE
Listings Requirements.
The REIT structure is a tax regime that allows a REIT to deduct qualifying distributions paid to investors, in
determining its taxable income.
The cash distribution of 54.81000 cents per linked unit meets the requirements of a “qualifying distribution” for the
purposes of section 25BB of the Income Tax Act (a “qualifying distribution”) with the result that:
- qualifying distributions received by resident Vukile linked unitholders must be included in the gross income of
such linked unitholders (as a non-exempt dividend in terms of section 10(1)(k)(aa) of the Income Tax Act), with
the effect that the qualifying distribution is taxable as income in the hands of the Vukile linked unitholder.
These qualifying distributions are however exempt from dividend withholding tax;
- qualifying distributions received by non-resident Vukile linked unitholders will not be taxable as income and
instead will be treated as ordinary dividends but which are exempt in terms of the usual dividend exemptions
per section 10(1)(k) of the Income Tax Act. It should be noted that until 31 December 2013 qualifying
distributions received by non-residents are not subject to dividend withholding tax. From 1 January 2014, any
qualifying distribution will be subject to dividends tax.
Linked unitholders are advised that in electing to participate in the linked unit reinvestment alternative, pre-taxation
funds are utilised for the reinvestment purposes and that taxation will be due on the total cash distribution amount of
54.81000 cents per linked unit.
Other information:
- The ordinary issued share capital of Vukile is 478 352 223 ordinary shares of 1 cent each before any election to
reinvest the cash distribution.
- Income Tax Reference Number of Vukile: 9331/617/114/3.
The cash distribution or linked unit reinvestment alternative may have tax implications for resident as well as non-
resident linked unitholders. Linked unitholders are therefore encouraged to consult their professional advisors should
they be in any doubt as to the appropriate action to take.
15 November 2013
Corporate advisor and JSE sponsor NSX sponsor
Java Capital IJG Securities (Pty) Ltd
Date: 15/11/2013 12:06:00 Produced by the JSE SENS Department. The SENS service is an information dissemination service administered by the JSE Limited ('JSE').
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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.