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LODESTONE REIT LIMITED - Dividend: Tax treatment and salient dates

Release Date: 06/05/2015 13:53
Code(s): LDO     PDF:  
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Dividend:  Tax treatment and salient dates

Lodestone REIT Limited
(previously Lodestone Properties Limited)
(Incorporated in the Republic of South Africa)
Registration number: 2010/017830/06
JSE share code: LDO  ISIN: ZAE000197935
(Approved as a REIT by the JSE)
(“Lodestone”)


DIVIDEND: TAX TREATMENT AND SALIENT DATES


Shareholders are referred to Lodestone’s preliminary summarised audited consolidated financial statements
for the period ended 31 March 2015, published on SENS on Wednesday, 6 May 2015, and in particular, the
notification of a final dividend payment of 12.99000 cents per share for the period ended 31 March 2015
(“the dividend”).

In accordance with Lodestone’s status as a REIT, shareholders are advised that the dividend 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 dividend will be deemed to be a dividend for South African tax purposes,
in terms of section 25BB of the Income Tax Act.

The dividend received by or accrued to South African tax residents must be included in the gross income of
such shareholders 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 dividend is, however, exempt from dividend withholding tax in the hands of
South African tax resident shareholders, provided that the South African resident shareholders provided the
following forms to their Central Securities Depository Participant (“CSDP”) or broker, as the case may be,
in respect of uncertificated shares, or the company, in respect of certificated shares:

a)    a declaration that the dividend 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. Shareholders 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 dividend, if such documents have not
already been submitted.

Dividends received by non-resident shareholders 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 dividends received by
non-residents from a REIT were not subject to dividend withholding tax. Since 1 January 2014, any
dividend 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 shareholder. Assuming dividend withholding tax
will be withheld at a rate of 15%, the net dividend amount due to non-resident shareholders is
11.04150 cents per share. A reduced dividend withholding rate in terms of the applicable DTA, may only be
relied upon if the non-resident shareholder has provided the following forms to their CSDP or broker, as the
case may be, in respect of uncertificated shares, or the company, in respect of certificated shares:


a)    a declaration that the dividend 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
shareholders 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 dividend if such documents have not
already been submitted, if applicable.

The dividend is payable to Lodestone’s shareholders in accordance with the timetable set out below:

                                                                                                   2015
Last date to trade cum dividend:                                                         Friday, 22 May
Shares trade ex dividend:                                                                Monday, 25 May
Record date:                                                                             Friday, 29 May
Payment date:                                                                            Monday, 1 June

Shareholders certificates may not be dematerialised or rematerialised between Monday, 25 May 2015 and
Friday, 29 May 2015, both days inclusive.

Payment of the dividend will be made to shareholders on Monday, 1 June 2015. In respect of dematerialised
shares, the dividend will be transferred to the CSDP accounts/broker accounts on Monday, 1 June 2015.
Certificated shareholders’ dividend payments will be posted on or about Monday, 1 June 2015.

Shares in issue at the date of declaration of dividend: 143 461 366
Lodestone’ income tax reference number: 9555665166.

6 May 2015


Sponsor
Java Capital

Date: 06/05/2015 01:53:00 Produced by the JSE SENS Department. The SENS service is an information dissemination service administered by the JSE Limited ('JSE'). 
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