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’ unaudited results for the six months ended 28th February 2018, published on
SENS on Tuesday, 8 May 2018, and in particular, the declaration of the Rebosis A ordinary share dividend of 126.43
cents per share (dividend number 3) and Rebosis ordinary dividend of 63.23cents per share (dividend number 15)
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:
- 101.144 cents per Rebosis A ordinary share
- 50.584 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
The dividends are payable to Rebosis’ A ordinary and ordinary shareholders in accordance with the timetable set out
Last day to trade cum dividend Tuesday, 22 May
Shares trade ex dividend Wednesday, 23 May
Record date Friday, 25 May
Payment date Monday, 28 May
Share certificates may not be dematerialised or rematerialised between Wednesday, 23 May 2018 and Friday, 25 May
2018, both days inclusive. The dividend will be transferred to dematerialised shareholders’ CSDP accounts/broker
accounts on Monday, 28 May 2018. Certificated shareholders’ dividend payments will be paid to certificated
shareholders’ bank accounts on or about Monday, 28 May 2018.
Rebosis ordinary shares in issue at the date of declaration of dividend: 670 881 453*
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.
*net of 2 408 326 treasury shares
11 May 2018
Rand Merchant Bank, a division of FirstRand Bank Limited
Date: 11/05/2018 08:43:00 Produced by the JSE SENS Department. The SENS service is an information dissemination service administered by the JSE Limited ('JSE').
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