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Dividend: tax treatment and salient dates
REBOSIS PROPERTY FUND LIMITED
(Incorporated in the Republic of South Africa)
(Registration number 2010/003468/06)
JSE share codes: REA ISIN: ZAE000240552
REB ISIN: ZAE000201687
(Approved as a REIT by the JSE)
(“Rebosis” or “the company”)
DIVIDEND: TAX TREATMENT AND SALIENT DATES
Shareholders are referred to Rebosis’ unaudited results for the six months ended 28 February 2017, published on
SENS on Monday, 24 April 2017, and in particular, the notification of a gross dividend (dividend number 13) of
60.80334 cents per share (“the dividend”) referred to therein, and are advised as follows:
In accordance with Rebosis’ 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 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 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 it is a dividend distributed by a
REIT. This dividend is, however, exempt from dividend 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 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. On 22 February 2017, the dividends withholding tax rate was increased from 15% to 20% and
accordingly, any distribution received by a non-resident from a REIT will be subject to dividend withholding tax at
20%, 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 20%, the net dividend amount due to non-resident shareholders is 48.64268 cents per share. A
reduced dividend withholding rate in terms of the applicable DTA, may only be relied upon 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 distribution 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.
The dividend is payable to Rebosis’ shareholders in accordance with the timetable set out below:
2017
Last day to trade cum dividend Tuesday, 16 May
Shares trade ex dividend Wednesday, 17 May
Record date Friday, 19 May
Payment date Monday, 22 May
Shareholders may not dematerialise or rematerialise their shares between Wednesday, 17 May 2017 and Friday,
19 May 2017, both days inclusive. In respect of dematerialised shareholders, the dividend will be transferred to the
CSDP accounts/broker accounts on Monday, 22 May 2017. Certificated shareholders’ dividend payments will be
deposited on or about Monday, 22 May 2017.
Shares in issue at the date of declaration of dividend: 642 526 328.
Rebosis’ income tax reference number: 9170/052/18/8.
24 April 2017
Sponsor
Java Capital
Date: 24/04/2017 08:50:00 Produced by the JSE SENS Department. The SENS service is an information dissemination service administered by the JSE Limited ('JSE').
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