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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 condensed unaudited consolidated results for the six months ended 30 September 2015,
published on SENS on Wednesday, 4 November 2015, wherein shareholders were advised of the dividend payment of 21.58 cents
per share for the six months ended 30 September 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 18.34300 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, 27 November
Shares trade ex dividend: Monday, 30 November
Record date: Friday, 4 December
Payment date: Monday, 7 December
Share certificates may not be dematerialised or rematerialised between Monday, 30 November 2015 and Friday, 4 December 2015,
both days inclusive.
Payment of the dividend will be made to shareholders on Monday, 7 December 2015. In respect of dematerialised shares, the
dividend will be transferred to the CSDP accounts/broker accounts on Monday, 7 December 2015. Certificated shareholders’
dividend payments will be posted on or about Monday, 7 December 2015.
Shares in issue at the date of declaration of dividend: 143 461 366
Lodestone’ income tax reference number: 9555665166.
4 November 2015
Sponsor
Java Capital
Date: 04/11/2015 04:00:00 Produced by the JSE SENS Department. The SENS service is an information dissemination service administered by the JSE Limited ('JSE').
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