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REBOSIS PROPERTY FUND LIMITED - Payment of cash dividend: tax treatment and salient dates

Release Date: 10/11/2017 11:37
Code(s): REB REA     PDF:  
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Payment of cash 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”)


PAYMENT OF CASH DIVIDEND: TAX TREATMENT AND SALIENT DATES


Shareholders are referred to the Rebosis’ provisional reviewed condensed consolidated results for the year ended 31
August 2017, published on SENS on Thursday, 9 November 2017, and in particular, the declaration of the Rebosis A
ordinary share dividend of 120.40855 cents per share (dividend number 2) and Rebosis ordinary dividend of 67.54686
cents per share (dividend number 14) referred to therein, and are advised as follows:

In accordance with Rebosis’ status as a REIT, Rebosis A ordinary shareholders (“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 as follows:
    - 96.32684 cents per Rebosis A ordinary share
    - 54.03749 cents per Rebosis ordinary 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 dividends are payable to Rebosis’ A ordinary and ordinary shareholders in accordance with the timetable set out
below:

                                                                                                             2017
 Last day to trade cum dividend                                                              Tuesday, 28 November
 Shares trade ex dividend                                                                  Wednesday, 29 November
 Record date                                                                                   Friday, 1 December
 Payment date                                                                                  Monday, 4 December

Share certificates may not be dematerialised or rematerialised between Wednesday, 29 November 2017 and Friday, 1
December 2017, both days inclusive. The dividend will be transferred to dematerialised shareholders’ CSDP
accounts/broker accounts on Monday, 4 December 2017. Certificated shareholders’ dividend payments will be paid to
certificated shareholders’ bank accounts on or about Monday, 4 December 2017.


Rebosis ordinary shares in issue at the date of declaration of dividend: 642 316 328.
Rebosis A ordinary shares in issue at the date of declaration of dividend: 63 266 012
Rebosis’ income tax reference number: 9170/052/18/8.

10 November 2017

Sponsor
Rand Merchant Bank, a division of FirstRand Bank Limited

Date: 10/11/2017 11:37:00 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.

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