ARROWHEAD PROPERTIES LIMITED - Dividend for the quarter ended 30 June 2017 - Salient dates and tax treatment

Dividend for the quarter ended 30 June 2017 - Salient dates and tax treatment

ARROWHEAD PROPERTIES LIMITED
(Incorporated in the Republic of South Africa)
(Registration number 2011/000308/06)
JSE share code: AWA ISIN: ZAE000203105
(Approved as a REIT by the JSE)
(“Arrowhead” or “the company”)


DIVIDEND FOR THE QUARTER ENDED 30 JUNE 2017 - SALIENT DATES AND TAX TREATMENT


The board of directors has approved, and notice is hereby given, of a cash dividend (dividend number 23) of 22.05 cents
per ordinary share for the quarter ended 30 June 2017, in accordance with the salient dates set out below:

                                                                                                                2017
Last day to trade cum dividend                                                                 Tuesday, 12 September
Shares trade ex dividend                                                                     Wednesday, 13 September
Record date                                                                                     Friday, 15 September
Payment date                                                                                    Monday, 18 September

Share certificates may not be dematerialised or rematerialised between Wednesday, 13 September 2017 and Friday,
15 September 2017, both days inclusive.

Payment of the dividend will be made to shareholders on Monday, 18 September 2017. In respect of dematerialised
shares, the dividend will be transferred to the Central Securities Depository Participant (“CSDP”) accounts/broker
accounts on Monday, 18 September 2017. Certificated shareholders’ dividend payments will be deposited on or about
Monday, 18 September 2017.

TAX TREATMENT OF DIVIDEND

In accordance with Arrowhead’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 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. The 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 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. From 22 February 2017, 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 17.64 cents per ordinary
share. A reduced dividend withholding rate in terms of the applicable DTA, may only be relied on if the non-resident
shareholder qualifies for exemption and has provided the following forms to its CSDP or broker, as the case may be, in
respect of uncertificated shareholders, or the company, in respect of certificated shareholders:

      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.

Ordinary shares in issue at the date of declaration of this dividend: 1 037 915 775
Arrowhead’s income tax reference number: 9779/439/15/8

23 August 2017


Sponsor
Java Capital
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