DELTA PROPERTY FUND LIMITED - Tax implications

Tax implications

Delta Property Fund Limited
(Incorporated in the Republic of South Africa)
(Registration number 2002/005129/06)
Share code: DLT ISIN: ZAE000194049
("Delta" or “the Fund” or “the Group”)
(REIT status approved)

Tax implications

Further to the unaudited condensed consolidated interim results for the six months ended 31 August
2016 released on SENS today, set out below the tax implications for the dividend payment.

Tax implications for South African resident shareholders
Dividends received by or accrued to South African tax residents must be included in the gross income
of such shareholders and are not exempt from income tax in terms of the exclusion to the general
dividend exemption contained in Section 10(1)(k)(i)(aa) of the Income Tax Act because they are
dividends distributed by a REIT. These dividends are, however, exempt from dividend withholding tax
(“Dividend Tax”) in the hands of South African resident shareholders provided that the South African
resident shareholders have provided to the CSDP or broker, as the case may be, in respect of
dematerialised shares, or the transfer secretaries, in respect of certificated shares, a DTD (EX)
(Dividend Tax : Declaration and undertaking to be made by the beneficial owner of a share) form to
prove their status as a South African resident and indicating the exemption upon which they are
relying.

If resident shareholders have not submitted the abovementioned documentation to confirm their
status as a South African resident, they are advised to contact their CSDP or broker, as the case may
be, to arrange for the documents to be submitted prior to the payment of the dividend.

Tax implications for non-resident shareholders
Dividends received by non-resident shareholders from a REIT will not be taxable as income and will be
exempt from income tax in terms of the exemption in Section 10(1)(k)(i) of the Income Tax Act. With
effect from 1 January 2014, any dividend received by a non-resident from a REIT will be subject to
Dividend 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 non-resident
shareholder. Assuming Dividend Tax will be withheld at the current rate of 15%, the net dividend
amount due to non-resident shareholders is 39.04098 cents per share. A reduced Dividend Tax rate in
terms of the applicable DTA, may only be relied on if the non-resident shareholder has provided the
following forms to the CSDP or broker, as the case may be, in respect of dematerialised shares, or the
transfer secretaries, 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 the CSDP, broker or the transfer secretaries, 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.

If applicable, non-resident shareholders are advised to contact their CSDP, broker or the transfer
secretaries, 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.
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710 632 182 Delta shares are in issue at the date of this dividend declaration and Delta’s income tax
reference number is 9464252148.

27 October 2016

Sponsor
Nedbank Corporate and Investment Banking




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