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Distributions: Tax treatment and salient dates
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”)
DISTRIBUTIONS: TAX TREATMENT AND SALIENT DATES
Linked unitholders are referred to Ascension’s condensed unaudited consolidated interim results for the six
months ended 31 December 2014, published on SENS on 2 March 2015, wherein linked unitholders were
advised of distributions no. 6 of 20.94750 cents per A-linked unit and 11.27673 cents per B-linked unit for
the six months ended 31 December 2014 (“the distributions”).
In accordance with Ascension’s status as a REIT, linked unitholders are advised that the distributions meet
the requirements of “qualifying distributions” 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 a dividend 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 Ascension, 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 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 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. Since 1 January 2014,
any distributions received by a non-resident from a REIT are 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 17.80538 cents per A-linked unit and 9.58522 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 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 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 distributions if such documents have not
already been submitted, if applicable.
The distributions are payable to Ascension linked unitholders in accordance with the timetable set out
below:
2015
Last date to trade cum distribution: Friday, 20 March
Linked units trade ex distribution: Monday, 23 March
Record date: Friday, 27 March
Payment date: Monday, 30 March
Linked unit certificates may not be dematerialised or rematerialised between Monday, 23 March 2015 and
Friday, 27 March 2015, both days inclusive.
Payment of the distributions will be made to linked unitholders on Monday, 30 March 2015. In respect of
dematerialised linked units, the distributions will be transferred to the CSDP accounts/broker accounts on
Monday, 30 March 2015. Certificated linked unitholders’ distributions payments will be posted on or about
Monday, 30 March 2015.
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
2 March 2015
Sponsor
Java Capital
Date: 02/03/2015 01:02:00 Produced by the JSE SENS Department. The SENS service is an information dissemination service administered by the JSE Limited ('JSE').
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