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Dividend: Tax treatment and salient dates
CAPITAL PROPERTY FUND LIMITED
(previously Friedshelf 1497 Proprietary Limited)
(Incorporated in the Republic of South Africa)
(Registration number 2013/226575/06)
(Approved as a REIT by the JSE)
JSE share code: CPF ISIN: ZAE000186821
(“Capital” or the “company”)
DIVIDEND: TAX TREATMENT AND SALIENT DATES
Shareholders are referred to Capital’s condensed unaudited consolidated interim financial statements for the six
months ended 30 June 2015, published on SENS on 29 July 2015, wherein shareholders were advised of the dividend
of 42.77 cents per share for the six months ended 30 June 2015 (“the dividend”), and are advised as follows:
In accordance with Capital’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 on the shares 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. From 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 36.3545 cents per share. A reduced dividend withholding rate in terms of the applicable
DTA, may only be relied on 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 Capital shareholders in accordance with the timetable set out below:
2015
Last date to trade cum dividend: Friday, 21 August
Shares trade ex dividend: Monday, 24 August
Record date: Friday, 28 August
Payment date: Monday, 31 August
Share certificates may not be dematerialised or rematerialised between Monday, 24 August 2015 and Friday,
28 August 2015, both days inclusive.
Payment of the dividend will be made to shareholders on Monday, 31 August 2015. In respect of dematerialised
shares, the dividend will be transferred to the CSDP accounts/broker accounts on Monday, 31 August 2015.
Certificated shareholders’ dividend payments will be posted on or about Monday, 31 August 2015.
Shares in issue at the date of declaration of this dividend: 1 772 624 329
Capital’s income tax reference number: 9096565198
29 July 2015
Sponsor
Java Capital
Date: 29/07/2015 03:25:00 Produced by the JSE SENS Department. The SENS service is an information dissemination service administered by the JSE Limited ('JSE').
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