INVESTEC PROPERTY FUND LIMITED - Clarification regarding the tax treatment of dividend declared

Clarification regarding the tax treatment of dividend declared

INVESTEC PROPERTY FUND LIMITED
Approved as a REIT by the JSE
(Incorporated in the Republic of South Africa)
(Registration Number 2008/011366/06)
Share code: IPF     ISIN: ZAE000180915
(“Investec Property Fund” or “the Fund”)


              CLARIFICATION REGARDING THE TAX TREATMENT OF DIVIDEND DECLARED


The announcement released on the 21 November 2013 regarding the reviewed interim condensed
financial results for the six months to 30 September 2013 included reference to a dividend declared.

Investec Property Fund 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 (“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 Fund’s distribution of 50.4613 cents per share meets the requirements of a “qualifying distribution”
for the purposes of section 25BB of the Income Tax Act (“qualifying distribution”) with the result that:

    -   qualifying distributions received by resident Investec Property Fund shareholders must be
        included in the gross income of such shareholders (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 Investec Property Fund shareholder. These qualifying distributions
        are however exempt from dividend withholding tax;

    -   qualifying distributions received by non-resident Investec Property Fund shareholders 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.

Shareholders, both South African resident and non-resident taxpayers, are encouraged to consult their
professional tax advisors with regard to their individual tax liability in this regard.


Johannesburg
22 November 2013

Sponsor
Investec Corporate Finance

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