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Interest distributions for the quarter ended 30 June 2014 – salient dates
ARROWHEAD PROPERTIES LIMITED
(Incorporated in the Republic of South Africa)
(Registration number 2011/000308/06)
JSE share code: AWA ISIN: ZAE000158101
JSE share code: AWB ISIN: ZAE000158119
(Approved as a REIT by the JSE)
(“Arrowhead” or “the company”)
INTEREST DISTRIBUTIONS FOR THE QUARTER ENDED 30 JUNE 2014 – SALIENT DATES
The board of directors has approved and notice is hereby given of cash interest distributions (distribution number 11) of 17.115 cents
per A-linked unit and 17.115 cents per B-linked unit for the quarter ended 30 June 2014, growth of 19.93% on the same quarter of
2013, in accordance with the salient dates set out below:
2014
Last date to trade cum distribution Friday, 29 August
Linked units trade ex distribution Monday, 1 September
Record date Friday, 5 September
Payment date Monday, 8 September
Linked unit certificates may not be dematerialised or rematerialised between Monday, 1 September 2014 and Friday,
5 September 2014, both days inclusive.
As Arrowhead has Real Estate Investment Trust (“REIT”) status with the JSE Limited (“JSE”), linked unitholders are advised that
the distributions meet the requirements of a “qualifying distribution” for the purposes of section 25BB of the Income Tax Act, No. 58
of 1962 (“Income Tax Act”). The distributions on the linked units will be deemed to be dividends, for South African tax purposes, in
terms of section 25BB of the Income Tax Act.
The distributions received by or accrued to South African tax residents must be included in the gross income of such linked
unitholders and will not be exempt from income tax (in terms of the exclusion to the general dividend exemption, contained in
paragraph (aa) of section 10(1)(k)(i) of the Income Tax Act) because they are dividends distributed by a REIT. These distributions
are, however, exempt from dividend withholding tax in the hands of South African tax resident linked unitholders, provided that the
South African resident linked unitholders provided the following forms to the Central Securities Depository Participant (“CSDP”) or
broker, as the case may be, in respect of uncertificated linked units, or the company, in respect of certificated linked units:
a) a declaration that the distribution is exempt from dividends tax; and
b) 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 unitholders are advised to contact
the 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.
Distributions received by non-resident linked unitholders will not be taxable as income and instead will be treated as ordinary
dividends which are exempt from income tax in terms of the general dividend exemption in section 10(1)(k)(i) of the Income Tax Act.
It should be noted that up to 30 June 2014 distributions received by non-residents from a REIT were not subject to dividend
withholding tax. From 1 January 2014, any distribution received by a non-resident from a REIT will be subject to dividend
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 linked unitholder. Assuming dividend withholding tax will be withheld at a
rate of 15%, the net dividend amount due to non-resident linked unitholders is 14.54775 cents per A-linked unit and 14.54775 cents
per B-linked unit. A reduced dividend withholding rate in terms of the applicable DTA, may only be relied on if the non-resident
linked unitholder has provided the following forms to the CSDP or broker, as the case may be, in respect of uncertificated linked
units, or the company, in respect of certificated linked units:
a) a declaration that the distribution is subject to a reduced rate as a result of the application of a DTA; and
b) a written undertaking to inform the 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 unitholders are advised
to contact the 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.
Linked unitholders are encouraged to consult their professional advisors should they be in any doubt as to the appropriate action to
take.
A -linked units in issue at the date of declaration of interim distribution: 377 358 252
B-linked units in issue at the date of declaration of interim distribution: 377 358 252
Arrowhead income tax reference number: 9779/439/15/8
11 August 2014
Sponsor
Java Capital
Date: 11/08/2014 11:37:00 Produced by the JSE SENS Department. The SENS service is an information dissemination service administered by the JSE Limited ('JSE').
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