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ARROWHEAD PROPERTIES LIMITED - Distribution for the quarter ended 31 December 2014 - salient dates and tax treatment

Release Date: 10/02/2015 08:22
Code(s): AWB AWA     PDF:  
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Distribution for the quarter ended 31 December 2014 - salient dates and tax treatment

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”)


DISTRIBUTION FOR THE QUARTER ENDED 31 DECEMBER 2014 - SALIENT DATES AND TAX TREATMENT


The board of directors has approved and notice is hereby given of cash distributions (distribution number 13) of 18.545
cents per A-linked unit (an increase of 22.81% over the 15.10 cents paid in the same quarter in the previous financial
year) and 18.545 cents per B-linked unit (an increase of 22.81% over the 15.10 cents paid in the same quarter in the
previous financial year) for the quarter ended 31 December 2014, in accordance with the salient dates set out below:

                                                                                                                 2015
Last date to trade cum distribution                                                               Friday, 27 February
Linked units trade ex distribution                                                                    Monday, 2 March
Record date                                                                                           Friday, 6 March
Payment date                                                                                          Monday, 9 March

Linked unit certificates may not be dematerialised or rematerialized between Monday, 2 March 2015 and Friday,
6 March 2015.

TAX TREATMENT OF DISTRIBUTION

In accordance with Arrowhead’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 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 distribution 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
their 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 distributions 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 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.

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 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 linked unitholder.
Assuming dividend withholding tax will be withheld at a rate of 15%, the net distribution amount due to non-resident
linked unitholders is 15.76325 cents per A-linked unit and 15.76325 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 their 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 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 unitholders
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.

A-linked units in issue at the date of declaration of this distribution: 386 464 320
B-linked units in issue at the date of declaration of this distribution: 386 464 320
Arrowhead’s income tax reference number: 9779/439/15/8

10 February 2015


Sponsor

Java Capital

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