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Distribution: tax treatment and salient dates
REBOSIS PROPERTY FUND LIMITED
(Incorporated in the Republic of South Africa)
(Registration number 2010/003468/06)
JSE share code: REB ISIN: ZAE000156147
(Approved as a REIT by the JSE)
(“Rebosis” or “the company”)
DISTRIBUTION: TAX TREATMENT AND SALIENT DATES
The board has approved and notice is hereby given of a distribution of 14.41779 cents per share for the year ended
31 August 2015.
In accordance with the company’s status as a REIT, shareholders are advised that the distribution 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 distribution 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 distribution 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 distribution 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 distribution 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 distribution, if such documents have not already been submitted.
Distributions 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 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
shareholders. Assuming dividend withholding tax will be withheld at a rate of 15%, the net dividend amount due to
non-resident shareholders is 12.25512 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 distribution if such documents have not already been submitted, if
applicable.
The distribution is payable to Rebosis shareholders in accordance with the timetable set out below:
2015
Last day to trade cum distribution: Friday, 13 November
Shares trade ex distribution: Monday, 16 November
Record date: Friday, 20 November
Payment date: Monday, 23 November
Share certificates may not be dematerialised or rematerialised between Monday, 16 November 2015 and Friday,
20 November 2015, both days inclusive.
Payment of the distribution will be made to shareholders on Monday, 23 November 2015. In respect of dematerialised
shareholders, the distribution will be transferred to the CSDP accounts/broker accounts on Monday,
23 November 2015. Certificated shareholders’ distribution payments will be posted on or about Monday,
23 November 2015.
Shares in issue at the date of declaration of this distribution: 518 169 396
Rebosis’ income tax reference number: 9170/052/18/8.
28 October 2015
Sponsor
Java Capital
Date: 28/10/2015 08:56:00 Produced by the JSE SENS Department. The SENS service is an information dissemination service administered by the JSE Limited ('JSE').
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