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Dividend: Tax treatment and salient dates
FORTRESS INCOME FUND LIMITED
(Incorporated in the Republic of South Africa)
(Registration number 2009/016487/06)
JSE share codes: FFA ISIN: ZAE000192787
FFB ISIN: ZAE000192795
(Approved as a REIT by the JSE)
(“Fortress”)
DIVIDEND: TAX TREATMENT AND SALIENT DATES
Shareholders are referred to Fortress’ preliminary summarised audited consolidated financial statements for the year
ended 30 June 2016, published on SENS on 11 August 2016, wherein shareholders were advised of the dividends of
64.45 cents per A share and 74.69 cents per B share for the six months ended 30 June 2016 (“the dividends”).
In accordance with Fortress’ status as a REIT, shareholders are advised that the dividends meet 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 dividends 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 dividends 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. These dividends are, 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 dividends, 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 54.78250 cents per A share and 63.48650 cents per B 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 dividends if such documents have not already been submitted, if
applicable.
The dividends are payable to Fortress shareholders in accordance with the timetable set out below:
2016
Last date to trade cum dividend: Tuesday, 6 September
Shares trade ex dividend: Wednesday, 7 September
Record date: Friday, 9 September
Payment date: Monday, 12 September
Share certificates may not be dematerialised or rematerialised between Wednesday, 7 September 2016 and Friday,
9 September 2016, both days inclusive.
Payment of the dividends will be made to shareholders on Monday, 12 September 2016. In respect of dematerialised
shares, the dividends will be transferred to the CSDP accounts/broker accounts on Monday, 12 September 2016.
Certificated shareholders’ dividend payments will be deposited on or about Monday, 12 September 2016.
A shares in issue at the date of declaration of the dividend: 1 119 708 334
B shares in issue at the date of declaration of the dividend: 1 014 226 190
Fortress’ income tax reference number: 9218846179
11 August 2016
Sponsor
Java Capital
Date: 11/08/2016 03:02:00 Produced by the JSE SENS Department. The SENS service is an information dissemination service administered by the JSE Limited ('JSE').
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