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Second Cash Distribution Announcement- RDFIHG
INVESTEC WARRANTS
JSE SHARE CODE: RDFIHG
JSE ISIN CODE: ZAE000187373
DECLARED CASH DISTRIBUTION ANNOUNCEMENT ON REDEFINE PROPERTIES LIMITED HOT ENHANCED DIVIDEND
SECURITIES – (“RDFIHG”)
The Directors of Redefine Properties Limited have declared a cash distribution of 36.40 cents payable on Monday,
02 June 2014 to ordinary holders recorded in the books of the company at the close of business on Friday, 30 May
2014.
Redefine Properties Limited was granted REIT status by the JSE Limited with effect from 1 September 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 36,40 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:
1) qualifying distributions received by resident Redefine linked unit-holders must be included in the gross
income of such linked unit-holders (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
Redefine linked unit-holder. These qualifying distributions are however exempt from dividends
withholding tax, provided that the South African resident linked unit-holders provided the following
forms to their CSDP or broker, as the case may be, in respect of uncertificated linked units, or the
company, in respect of certificated linked units:
2 a declaration that the distribution is exempt from dividends tax; and
3) a written undertaking to inform the CSDP, broker or the company, 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. Linked
unit-holders are advise to contact their CSDP, broker or the company, 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.
4) qualifying distributions received by non-resident Redefine linked unit-holders 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 section10(1)(k) of the Income Tax Act. It should be noted that until 31
December 2013 qualifying distributions received by non-residents were not subject to dividends
withholding tax. From 1 January 2014, any qualifying distribution will be subject to dividends withholding
tax at 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 unit-holder. Assuming
dividends withholding tax will be withheld at a rate of 15%, the net distribution amount due to non-
resident linked unit-holders is 30,94 cents per linked unit. A reduced dividends withholding rate in terms
of the applicable DTA, may only be relied upon if the non-resident linked unit-holder has provided the
following forms to their CSDP or broker, as the case may be, in respect of uncertificated linked units, or
the company, in respect of certificated linked units:
4.1. a declaration that the distribution is subject to a reduced rate as a result of the
application of a DTA; and
4.2. a written undertaking to inform their CSDP, broker or the company, 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 linked unit-
holders are advised to contact their CSDP, broker or the company, 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, if applicable.
In terms of the new Dividend Tax effective 1 April 2012, the following additional information is disclosed:
1) local dividend tax rate is 15%;
2) No STC credits utilised;
3) the issued share capital of Redefine Properties Limited is 3,070,978,269 ordinary shares;
4) Redefine Properties Limited tax reference number 917/852/484/0; and
Investec Bank Limited tax reference number is 9675/053/71/5.
Accordingly, the holders of RDFIHG will receive a Redefine Properties Limited cash distribution of 36.40 cents per
security on, Monday, 02 June 2014 in terms of the Cession clause incorporated in the Supplement between the
holders and Investec Bank Limited. The last day to trade (“cum” the interest distribution) in order to participate in
the debenture interest distribution will be Friday, 23 May 2014.
RDFIHG Hot Enhanced Dividend Securities will commence trading “ex” the debenture interest distribution from the
commencement of business on Monday, 26 May 2014, and the record date will be Friday, 30 May 2014.
Date: 23 May 2014
Copies of the offering circular may be obtained from:
Investec Bank Limited
100 Grayston Drive
Sandown
Sandton
2196
For further information contact:
Investec Warrants
Tel.: 0860 103 343
E-mail: warrants@investec.co.za
Internet: www.investec.co.za
Sponsor:
Investec Securities Ltd
Member of the JSE
Registration number (1972/008905/06)
Date: 23/05/2014 04:44:00 Produced by the JSE SENS Department. The SENS service is an information dissemination service administered by the JSE Limited ('JSE').
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