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Dividend for the quarter ended 31 December 2016 - salient dates and tax treatment - GPA/GPB
GEMGROW PROPERTIES LIMITED
(previously Synergy Income Fund Limited)
(Incorporated in the Republic of South Africa)
(Registration number 2007/032604/06)
JSE share code: GPA ISIN: ZAE0000223269
JSE share code: GPB ISIN: ZAE0000223277
(Granted REIT status with the JSE)
(“Gemgrow” or “the company”)
DIVIDEND FOR THE QUARTER ENDED 31 DECEMBER 2016 - SALIENT DATES AND TAX TREATMENT
The board of directors has approved and notice is hereby given of a cash dividend (dividend number 1) of
24.84563 cents per A ordinary share and 17.84205 cents per B ordinary share for the quarter ended 31 December 2016, in
accordance with the salient dates set out below:
2017
Last date to trade cum dividend: Tuesday, 7 March
Shares trade ex dividend: Wednesday, 8 March
Record date: Friday, 10 March
Payment date: Monday, 13 March
Share certificates may not be dematerialised or rematerialised between Wednesday, 8 March 2017 and Friday, 10 March
2017 both days inclusive.
Payment of the dividend will be made to shareholders on Monday, 13 March 2017. In respect of dematerialised
shares, the dividend will be transferred to the CSDP accounts/broker accounts on Monday, 13 March 2017. Certificated
shareholders’ dividend payments will be deposited on or about Monday, 13 March 2017.
TAX TREATMENT
In accordance with Gemgrow’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 distribution on 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 they are dividends distributed by a
REIT. This dividend is, however, exempt from dividends withholding tax in the hands of South African tax resident
shareholders, provided that the South African resident shareholders provided 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 dividends
which are 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 is 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 21.11879 cents per A ordinary share and 15.16574 cents per B ordinary 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 distribution if such documents have not already been submitted, if applicable.
A ordinary shares in issue at the date of declaration of this dividend: 47 352 203
B ordinary shares in issue at the date of declaration of this dividend: 400 710 459
Gemgrow’s income tax reference number: 9068/723/17/1
16 February 2017
Sponsor
Java Capital
Date: 16/02/2017 10:46:00 Produced by the JSE SENS Department. The SENS service is an information dissemination service administered by the JSE Limited ('JSE').
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