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Payment of top-up distribution to Synergy A shareholders
SYNERGY INCOME FUND LIMITED
(Incorporated in the Republic of South Africa)
(Registration number 2007/032604/06)
JSE share code: SGA ISIN:ZAE000202883
JSE share code: SGB ISIN:ZAE000202891
(Approved as a REIT by the JSE)
(“Synergy” or “the company”)
PAYMENT OF TOP-UP DISTRIBUTION TO SYNERGY A SHAREHOLDERS
Shareholders are advised that the board of directors of Synergy has declared a top-up distribution of
1.11068 cents per A share to the interim distribution for the six months ended 30 September 2015 of
46.21209 cents per A share, as announced on SENS on 20 November 2015. The top-up distribution
serves to increase the interim distribution to A shareholders to 47.32277 cents per A share, as set out
in the company’s memorandum of incorporation.
The top-up distribution is payable to Synergy A shareholders in accordance with the timetable set out
below:
Last date to trade cum dividend: Thursday, 31 December 2015
Shares trade ex dividend: Monday, 4 January 2016
Record date: Friday, 8 January 2016
Payment date: Monday, 11 January 2016
Share certificates may not be dematerialised or rematerialised between Monday, 4 January 2016 and
Friday, 8 January 2016, both days inclusive.
Payment of the distribution will be made to A shareholders on Monday, 11 January 2016. In respect of
dematerialised shares, the dividends will be transferred to the CSDP accounts/broker accounts on
Monday, 11 January 2016. Certificated shareholders’ dividend payments will be posted on or about
Monday, 11 January 2016.
Synergy was granted REIT status by the JSE Limited with effect from 1 July 2013 in line with the
REIT structure as provided for in the Income Tax Act, No 58 of 1962, as amended (“the Income Tax
Act”) and section 13 of the JSE Listings Requirements. The REIT structure is a tax regime that allows
a REIT to deduct qualifying distributions paid to investors, in determining its taxable income.
The distribution of 1.11068 cents per A share meets the requirements of a “qualifying distribution” for
the purposes of section 25BB of the Income Tax Act (“a qualifying distribution”) with the result
that:
- Qualifying distributions received by resident Synergy shareholders must be included in the
gross income of such shareholders (as a non-exempt dividend in terms of section
10(1)(k)(i)(aa) of the Income Tax Act), with the effect that the qualifying distribution is
taxable as income in the hands of the Synergy shareholder. These qualifying distributions are,
however, exempt from dividends withholding tax, provided that the South African resident
shareholders 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 declaration that the distribution is exempt from dividends tax; and
- 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.
- Qualifying distributions received by non-resident Synergy shareholders will not be taxable as
income and instead will be treated as ordinary dividends but which are exempt in terms of the
usual dividend exemptions per section 10(1)(k) of the Income Tax Act. It should be noted that
from 1 January 2014, any qualifying distributions are subject to dividends 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 dividends withholding tax will be withheld at a rate of 15%, the net
distribution amount due to non-resident shareholders is 0.94408 cents per A 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 declaration that the distribution is subject to a reduced rate as a result of the application
of a DTA; and
- 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.
Shareholders are further advised that:
The issued share capital of Synergy is:
- 47 352 203 A shares
- 106 352 670 B shares.
Synergy’s tax reference number is 9068723171.
This cash distribution may have tax implications for resident as well as non-resident shareholders.
Shareholders are therefore encouraged to consult their tax and/or professional advisors should they be
in any doubt as to the appropriate action to take.
14 December 2015 www.synergyincomefund.com
Sponsor
Java Capital
Date: 14/12/2015 05:00:00 Produced by the JSE SENS Department. The SENS service is an information dissemination service administered by the JSE Limited ('JSE').
The JSE does not, whether expressly, tacitly or implicitly, represent, warrant or in any way guarantee the truth, accuracy or completeness of
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