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Distribution : Tax treatment and salient dates
DIPULA INCOME FUND LIMITED
(Incorporated in the Republic of South Africa)
(Registration number 2005/013963/06)
JSE share code: DIA ISIN: ZAE000158317
JSE share code: DIB ISIN: ZAE000158325
(Approved as a REIT by the JSE)
(“Dipula” or the “company”)
DISTRIBUTION: TAX TREATMENT AND SALIENT DATES
Linked unitholders are referred to Dipula’s reviewed provisional condensed consolidated financial statements
for the year ended 31 August 2014, published on SENS on 12 November 2014, wherein linked unitholders were
advised of distributions no. 7 of 43.75245 cents per A-linked unit and 40.99484 cents per B-linked unit for the
six months ended 31 August 2014 (“the distributions”).
In accordance with Dipula’s status as a REIT, 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 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 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. These distributions are, 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 Dipula, in respect of certificated units:
a) a declaration that the distributions are exempt from dividends tax; and
b) a written undertaking to inform the CSDP, broker or Dipula, 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 Dipula, as the case may be, to arrange for the abovementioned
documents to be submitted prior to payment of the distributions, 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 37.18958 cents per A-linked unit and
34.84561 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 Dipula, in respect of certificated units:
a) a declaration that the distributions are 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 Dipula, 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 Dipula, as the case may be, to arrange for the
abovementioned documents to be submitted prior to payment of the distributions if such documents have not
already been submitted, if applicable.
The distributions are payable to Dipula linked unitholders in accordance with the timetable set out below:
2014
Last date to trade cum distribution: Friday, 28 November
Linked units trade ex distribution: Monday, 1 December
Record date: Friday, 5 December
Payment date: Monday, 8 December
Linked unit certificates may not be dematerialised or rematerialised between Monday, 1 December 2014 and
Friday, 5 December 2014, both days inclusive.
Payment of the distributions will be made to linked unitholders on Monday, 8 December 2014. In respect of
dematerialised linked units, the distributions will be transferred to the CSDP accounts/broker accounts on
Monday, 8 December 2014. Certificated linked unitholders’ distribution payments will be posted on or about
Monday, 8 December 2014.
A-linked units in issue at the date of declaration of the distribution: 153 965 561
B-linked units in issue at the date of declaration of the distribution: 156 046 263
Dipula’s income tax reference number: 9743/798/14/3
12 November 2014
Sponsor
Java Capital
Date: 12/11/2014 12:02:00 Produced by the JSE SENS Department. The SENS service is an information dissemination service administered by the JSE Limited ('JSE').
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