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Clarity on dividend tax treatment
Wilderness Holdings Limited
(Registration number 2004/2986)
(Registered as an external company in South Africa Registration number 2009/022894/10)
ISIN: BW0000000868
Share code: WIL
(“Wilderness” or “the Company”)
CLARITY ON DIVIDEND TAX TREATMENT
Notice is hereby given clarifying the treatment of final dividends declared by Wilderness Holdings in respect of the
years ended 28 February 2015, 28 February 2014 and 28 February 2013. Botswana dividends withholding tax of 7.5%
would not have been applicable in respect of these dividends as Wilderness Holdings was registered as an IFSC
company in Botswana during these financial years. South African dividends withholding tax at a rate of 15% would
have been levied on foreign dividends paid to shareholders who are not subject to any exemptions or reductions in
respect of the South African dividends withholding tax.
Tax implications for non-resident shareholders on the South African branch register:
Foreign dividends received by non-resident shareholders on the South African branch register during these financial
years would have been subject to South African dividends withholding tax at 15%, unless the rate was reduced in
terms of any applicable agreement for the avoidance of double taxation between South Africa and the country of
residence of the non-resident shareholder (DTA: Double Tax Agreement) or if any specific exemption applied. A
reduced dividend withholding rate in terms of the applicable DTA or the foreign dividend exemption in section 64F(j)
would only have been relied on if the non-resident shareholder provided the following forms (both in the form
prescribed by the Commissioner of the South African Revenue Services) to their Central Securities Depository
Participant (CSDP) or broker, as the case may be, in respect of certificated shares before the date of payment of the
relevant dividend:
– A declaration that the dividend was subject to a reduced rate as a result of the application of the DTA before
the date of payment of the relevant dividend; and
– A written undertaking to inform their CSDP or broker, as the case may be, should the circumstances affecting
the reduced rate have changed or the beneficial owner ceased to be the beneficial owner..
If applicable, where the applicable documents were not received by the date of payment of the relevant dividend,
and the reduced rate or exemption was not applied at the time the dividend was paid, the non-resident shareholders
are advised to contact their CSDP or broker, as the case may be, to arrange for the abovementioned documents to
be submitted in order for a refund of the over-withheld amount of dividends withholding tax. Please note that the
necessary documents must be submitted within three years after the date of payment of the relevant dividend.”
By Order of the Board
Gaborone, 10 August 2016
+267 392 6886
JSE Sponsor
RAND MERCHANT BANK (A division of First Rand Bank Limited)
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