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Tax treatment of distribution
ASCENSION PROPERTIES LIMITED
(Incorporated in the Republic of South Africa)
(Registration number 2006/026141/06)
JSE share code: AIA ISIN: ZAE000161881
JSE share code: AIB ISIN: ZAE000161899
(Approved as a REIT by the JSE)
(“Ascension” or “the company”)
TAX TREATMENT OF DISTRIBUTION
Linked unitholders are referred to Ascension’s condensed audited consolidated financial statements for the
year ended 30 June 2014, published on SENS on 29 August 2014, wherein linked unitholders were advised
of distributions no. 5 of 19.95 cents per A linked unit and 12.23 cents per B linked unit for the six months
ended 30 June 2014 (“the distribution”).
In accordance with Ascension’s status as a REIT, linked unitholders are advised that the distribution meets
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 distribution will be deemed to be a dividend for South African
tax purposes, in terms of section 25BB of the Income Tax Act.
The distribution received by or accrued to South African tax residents must be included in the gross
income of such 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 it is a dividend distributed by a REIT. This distribution is, however, exempt from dividend
withholding tax in the hands of South African tax resident unitholders, provided that the South African
resident unitholders provide the following forms to their Central Securities Depository Participant
(“CSDP”) or broker, as the case may be, in respect of uncertificated units, or Ascension, in respect of
certificated units:
a) a declaration that the distribution is exempt from dividends tax; and
b) a written undertaking to inform the CSDP, broker or Ascension, 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 their CSDP, broker or Ascension, 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 unitholders will not be taxable as income and instead will be treated
as an ordinary dividend which is 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 31 December 2013 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 unitholder. Assuming dividend
withholding tax will be withheld at a rate of 15%, the net distribution amount due to non-resident
unitholders is 16.95750 cents per A linked unit and 10.39550 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 unitholder has
provided the following forms to their CSDP or broker, as the case may be, in respect of uncertificated
units, or Ascension, in respect of certificated 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 their CSDP, broker or Ascension, 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
unitholders are advised to contact their CSDP, broker or Ascension, 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.
The distribution is payable to Ascension linked unitholders in accordance with the timetable set out below:
2014
Last date to trade cum distribution: Friday, 12 September
Linked units trade ex distribution: Monday, 15 September
Record date: Friday, 19 September
Payment date: Monday, 22 September
Linked unit certificates may not be dematerialised or rematerialised between Monday, 15 September 2014
and Friday, 19 September 2014, both days inclusive.
Payment of the distribution will be made to linked unitholders on Monday, 22 September 2014. In respect
of dematerialised linked units, the distribution will be transferred to the CSDP accounts/broker accounts on
Monday, 22 September 2014. Certificated linked unitholders’ distribution payments will be posted on or
about Monday, 22 September 2014.
A linked units in issue at the date of declaration of the distribution: 308 860 859
B linked units in issue at the date of declaration of the distribution: 376 359 014
Ascension’s income tax reference number: 9368 910 15 5
29 August 2014
Sponsor
Java Capital
Date: 29/08/2014 05:39:00 Produced by the JSE SENS Department. The SENS service is an information dissemination service administered by the JSE Limited ('JSE').
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