Wrap Text
Dividend: Tax treatment and salient dates
FORTRESS INCOME FUND LIMITED
(Incorporated in the Republic of South Africa)
(Registration number 2009/016487/06)
JSE share codes: FFA ISIN: ZAE000192787
FFB ISIN: ZAE000192795
(Approved as a REIT by the JSE)
(“Fortress” or “the company”)
DIVIDEND: TAX TREATMENT AND SALIENT DATES
Shareholders are referred to Fortress’ preliminary summarised audited consolidated financial statements for the year
ended 30 June 2017, published on SENS on 8 August 2017, wherein shareholders were advised of the gross
dividends of 67.67000 cents per A share and 93.41000 cents per B share for the six months ended 30 June 2017 (“the
dividends”).
In accordance with Fortress’ status as a REIT, shareholders are advised that the dividends 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 dividends on the shares 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 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 54.13600 cents per A
share and 74.72800 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 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 dividend if such documents have not already been submitted, if
applicable.
The dividend is payable to Fortress shareholders in accordance with the timetable set out below:
2017
Last date to trade cum dividend: Tuesday, 5 September 2017
Shares trade ex dividend: Wednesday, 6 September 2017
Record date: Friday, 8 September 2017
Payment date: Monday, 11 September 2017
Share certificates may not be dematerialised or rematerialised between Wednesday, 6 September 2017 and Friday,
8 September 2017, both days inclusive.
Payment of the dividend will be made to shareholders on Monday, 11 September 2017. In respect of dematerialised
shares, the dividend will be transferred to the CSDP accounts/broker accounts on Monday, 11 September 2017.
Certificated shareholders’ dividend payments will be deposited on or about Monday, 11 September 2017.
A shares in issue at the date of declaration of the dividend: 1 175 214 835
B shares in issue at the date of declaration of the dividend: 1 076 832 691
Fortress’ income tax reference number: 9218846179
8 August 2017
Sponsor
Java Capital
Date: 08/08/2017 04:40:00 Produced by the JSE SENS Department. The SENS service is an information dissemination service administered by the JSE Limited ('JSE').
The JSE does not, whether expressly, tacitly or implicitly, represent, warrant or in any way guarantee the truth, accuracy or completeness of
the information published on SENS. The JSE, their officers, employees and agents accept no liability for (or in respect of) any direct,
indirect, incidental or consequential loss or damage of any kind or nature, howsoever arising, from the use of SENS or the use of, or reliance on,
information disseminated through SENS.
Sharenet Sites 
