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Dividend: Tax treatment and salient dates
RESILIENT REIT LIMITED
(previously Resilient Property Income Fund Limited)
(Incorporated in the Republic of South Africa)
(Registration number 2002/016851/06)
JSE share code: RES ISIN: ZAE000209557
(Approved as a REIT by the JSE)
(“Resilient” or “the company”)
DIVIDEND: TAX TREATMENT AND SALIENT DATES
Shareholders are referred to Resilient’s preliminary summarised audited consolidated financial statements for the
year ended 30 June 2016, published on SENS on 4 August 2016, wherein shareholders were advised of the
dividend of 256.27 cents per share for the six months ended 30 June 2016 (“the dividend”).
In accordance with Resilient’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 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. 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 217.82950 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 Resilient shareholders in accordance with the timetable set out below:
2016
Last date to trade cum dividend: Tuesday, 30 August
Shares trade ex dividend: Wednesday, 31 August
Record date: Friday, 2 September
Payment date: Monday, 5 September
Share certificates may not be dematerialised or rematerialised between Wednesday, 31 August 2016 and Friday,
2 September 2016, both days inclusive.
Payment of the dividend will be made to shareholders on Monday, 5 September 2016. In respect of dematerialised
shareholders, the dividend will be transferred to the CSDP accounts/broker accounts on Monday,
5 September 2016. Certificated shareholders’ dividend payments will be posted on or about Monday,
5 September 2016.
Shares in issue at the date of declaration of this dividend: 393 970 580
Resilient’s income tax reference number: 9579269144
4 August 2016
Sponsor
Java Capital
Date: 04/08/2016 05:06:00 Produced by the JSE SENS Department. The SENS service is an information dissemination service administered by the JSE Limited ('JSE').
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