TOWER PROPERTY FUND LIMITED - Tax Treatment of dividend distribution

Tax Treatment of dividend distribution

Tower Property Fund Limited
(formerlyReftin 1004 Proprietary Limited)
(Registration number 2012/066457/06)
JSE share code: TWR ISIN: ZAE000179040
(Approved as a REIT by the JSE)
(“Tower” or the “company”)


TAX TREATMENT OF DIVIDEND DISTRIBUTION


Shareholders are referred to Tower’s consolidated interim results released on SENS on 23 January 2014 and the dividend
distribution of 33 cents per share referred to therein and are advised as follows:

South African tax resident shareholders

The dividend distribution received by South African tax residents must be included in their gross income and will not be exempt
in terms of the ordinary dividend exemption in section 10(1)(k)(i) of the Income Tax Act No. 58 of 1962 (“the Act”)as a result of
paragraph (aa) of the proviso thereto which provides that dividends distributed by a REIT are not exempt from income tax.

The dividends received by South African tax residents will, however, be exempt from dividend withholding tax provided that the
shareholder has provided the following forms to their Central Securities Depository Participant (“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 their CSDP or broker, 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. South African tax resident
    shareholders are advised to contact their CSDP or broker, 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.

Non-resident shareholders for South African income tax purposes

The dividend distribution received by non-resident shareholders will be exempt from income tax in terms of section 10(1)(k)(i) of
the Act, but will be subject to dividend withholding tax. Dividend withholding tax is levied at a rate of 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 non-resident shareholder.

Assuming that dividend withholding tax will be withheld at a rate of 15%, the net dividend amount due to non-resident
shareholders is 28.05 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 resolute of the application of a DTA; and
    b) a written undertaking to inform the CSDP or broker, 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 or broker, as the case may be, to arrange for the abovementioned documents to be submitted
    prior to the payment of the distribution if such documents have not already been submitted.

Both resident and non-resident shareholders are encouraged to consult their professional advisors should they be in any doubt as
to the appropriate action to take.

31 January 2014


Sponsor

Java Capital

Date: 31/01/2014 05:42:00 Produced by the JSE SENS Department. The SENS service is an information dissemination service administered by the JSE Limited ('JSE'). 
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