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Dividend: 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: ZAE000201687
(Approved as a REIT by the JSE)
(“Rebosis” or “the company”)
DIVIDEND: TAX TREATMENT AND SALIENT DATES
Shareholders are referred to Rebosis’ unaudited results for the six months ended 29 February 2016, published on SENS
on 14 April 2016, wherein shareholders were advised of a gross dividend of 56.79236 cents per share (dividend no. 11),
for the six months ended 29 February 2016 (“the dividend”).
In accordance with Rebosis’ 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 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 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 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 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 48.27351 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 dividend if such documents have not already been submitted, if
applicable.
The dividend is payable to Rebosis shareholders in accordance with the timetable set out below:
2016
Last date to trade cum dividend: Friday, 6 May
Shares trade ex dividend: Monday, 9 May
Record date: Friday, 13 May
Payment date: Monday, 16 May
Share certificates may not be dematerialised or rematerialised between Monday, 9 May 2016 and Friday, 13 May 2016,
both days inclusive.
The dividend will be transferred to dematerialised shareholders’ CSDP accounts/broker accounts on Monday,
16 May 2016. Certificated shareholders’ dividend payments will be posted on or paid to certificated shareholders’ bank
accounts on or about, Monday, 16 May 2016.
Shares in issue at the date of declaration of this distribution: 518 169 396
Rebosis’ income tax reference number: 9170/052/18/8.
14 April 2016
Sponsor
Java Capital
Date: 14/04/2016 07:06:00 Produced by the JSE SENS Department. The SENS service is an information dissemination service administered by the JSE Limited ('JSE').
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