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 reviewed provisional condensed consolidated financial results for the year ended 28
February 2017 released on SENS on 29 May 2017, set out below the tax implication for the dividend
payment of 51.30719 cents per share.

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
uncertificated shares, or the transfer secretaries, in respect of certificated shares:

a) a declaration that the distribution is exempt from dividends tax; and

b) a written undertaking to inform the CSDP, broker or the transfer secretaries, as the case may be,
   should the circumstances affecting the exemption change or the beneficial owner ceases to be
   the beneficial owner,

both in the form prescribed by the Commissioner for the South African Revenue Service. 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 22 February 2017, any dividend received by a non-resident from a REIT will be subject to
Dividend 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 non-resident
shareholder. Assuming Dividend Tax will be withheld at a rate of 20%, the net dividend amount due
to non-resident shareholders is 41.04575 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 uncertificated 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.

710 632 182 Delta shares are in issue at the date of this dividend declaration and Delta’s income tax
reference number is 9464252148.

29 May 2017

Sponsor: Nedbank Corporate and Investment Banking



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