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Distribution for the quarter ended 31 December 2015 - Salient dates and tax treatment
INDLUPLACE PROPERTIES LIMITED
(Previously Arrowhead Residential Limited)
(Incorporated in the Republic of South Africa)
(Registration number 2013/226082/06)
JSE share code: ILU ISIN: ZAE000201125
(Approved as a REIT by the JSE)
(“Indluplace” or “the company”)
DISTRIBUTION FOR THE QUARTER ENDED 31 DECEMBER 2015 - SALIENT DATES AND TAX TREATMENT
The board of directors has approved the distribution for the quarter ended 31 December 2015. Notice is hereby given of a
cash distribution (distribution number 3) of 22,93067 cents per share for the quarter ended 31 December 2015, in
accordance with the salient dates set out below:
2016
Last date to trade cum distribution Friday, 26 February
Shares trade ex distribution Monday, 29 February
Record date Friday, 4 March
Payment date Monday, 7 March
Share certificates may not be dematerialised or rematerialised between Monday, 29 February 2016 and Friday,
4 March 2016.
TAX TREATMENT OF DISTRIBUTION
In accordance with Indluplace’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 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 they are dividends distributed by a
REIT. This distribution is, however, exempt from distribution 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 dividends
which are 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 is 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 distribution amount due to non-resident shareholders is
19,49107 cents per share. A reduced dividend withholding rate in terms of the applicable DTA, may only be relied on if
the non-resident shareholders has provided the following forms to their CSDP or broker, as the case may be, in respect of
uncertificated shareholders, or the company, in respect of certificated shareholders:
a) a declaration that the distribution 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.
Shares in issue at the date of declaration of this distribution: 240 234 907
Indluplace’s income tax reference number: 9390/649/177
10 February 2016
Sponsor
Java Capital
Date: 10/02/2016 12:45:00 Produced by the JSE SENS Department. The SENS service is an information dissemination service administered by the JSE Limited ('JSE').
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