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Dividend: Tax treatment and salient dates
DIPULA INCOME FUND LIMITED
(Incorporated in the Republic of South Africa)
(Registration number 2005/013963/06)
JSE share code: DIA ISIN: ZAE000203378
JSE share code: DIB ISIN: ZAE000203394
(Approved as a REIT by the JSE)
(“Dipula” or “the company”)
DIVIDEND: TAX TREATMENT AND SALIENT DATES
Shareholders are referred to Dipula’s reviewed provisional condensed consolidated financial results for the year
ended 31 August 2016, published on SENS today, 9 November 2016, wherein shareholders were advised of gross
final dividend (dividend number 11) of 48.23707 cents per A-share and 50.71217 cents per B-share for the period
1 March 2016 to 31 August 2016 (“the dividends”).
In accordance with Dipula’s 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”) and will be deemed to be dividends, 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. The dividends are, however, exempt from dividend withholding tax in the hands of South African tax
resident shareholders, provided that such 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 dividends are 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 41.00151 cents per A-share and 43.10534 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 dividends are 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 Dipula shareholders in accordance with the timetable set out below:
2016
Last date to trade cum dividend: Tuesday, 6 December
Shares trade ex dividend: Wednesday, 7 December
Record date: Friday, 9 December
Payment date: Monday, 12 December
Share certificates may not be dematerialised or rematerialised between Wednesday, 7 December 2016 and Friday,
9 December 2016, both days inclusive.
The dividend will be transferred to dematerialised shareholders’ CSDP accounts/broker accounts on Monday,
12 December 2016. Certificated shareholders’ dividend payments will be paid to certificated shareholders’ bank
accounts on or about, Monday, 12 December 2016.
Dipula shareholders will be offered an election, in respect of all or part of their shareholding, to re-invest the cash
dividend of 48.23707 cents per A-share and 50.71217 cents per B-share in return for A-shares or B-shares, as the
case may be (“the re-investment option”), further details of which will be set out in a circular to shareholders to
be issued on or about 17 November 2016 and an announcement in this regard will be released on SENS.
A-shares in issue at the date of declaration of the dividends: 206 852 463
B-shares in issue at the date of declaration of the dividends: 206 852 463
Dipula’s income tax reference number: 9743/798/14/3
9 November 2016
Sponsor
Java Capital
Date: 09/11/2016 08:01:00 Produced by the JSE SENS Department. The SENS service is an information dissemination service administered by the JSE Limited ('JSE').
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