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Dividend : Tax treatment and salient dates
DIPULA INCOME FUND LIMITED
(Incorporated in the Republic of South Africa)
(Registration number 2005/013963/06)
JSE share code: DIA ISIN: ZAE000203378
JSE share code: DIB ISIN: ZAE000203394
(Approved as a REIT by the JSE)
(“Dipula” or “the company”)
DIVIDEND: TAX TREATMENT AND SALIENT DATES
Shareholders are referred to Dipula’s reviewed condensed consolidated results for the year ended 31 August 2015,
published on SENS on 11 November 2015, wherein shareholders were advised of dividends no. 9 of 45.94007 cents
per A share and 44.95016 cents per B share for the year ended 31 August 2015 (“the dividends”).
In accordance with Dipula’s status as a REIT, shareholders are advised that the dividends meet the requirements of a
“qualifying distribution” for the purposes of section 25BB of the Income Tax Act, No. 58 of 1962 (“Income Tax
Act”) and will be deemed to be dividends, for South African tax purposes, in terms of section 25BB of the Income
Tax Act.
The dividends 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 they are dividends distributed by a
REIT. The dividends are, however, exempt from dividend withholding tax in the hands of South African tax resident
shareholders, provided that such shareholders provide 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 dividends are 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 39.04906 cents per A share and 38.20764 cents per B 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 dividends 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 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 dividends if such documents have not already been submitted, if
applicable.
The dividends are payable to Dipula 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 dividends will be made to shareholders on Monday, 7 December 2015. In respect of dematerialised
shares, the dividends 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.
A shares in issue at the date of declaration of the dividends: 202 178 537
B shares in issue at the date of declaration of the dividends: 203 351 039
Dipula’s income tax reference number: 9743/798/14/3
11 November 2015
Sponsor
Java Capital
Date: 11/11/2015 12:14:00 Produced by the JSE SENS Department. The SENS service is an information dissemination service administered by the JSE Limited ('JSE').
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