DIPULA INCOME FUND LIMITED - Dividend: Tax treatment and salient dates

Release Date: 21/05/2018 10:01
Code(s): DIA DIB
 
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Dividend: Tax treatment and salient dates

DIPULA INCOME FUND LIMITED
(Incorporated in the Republic of South Africa)
(Registration number 2005/013963/06)
JSE share code: DIA   ISIN:ZAE000203378
JSE share code: DIB   ISIN:ZAE000203394
(Approved as a REIT by the JSE)
(“Dipula” or “the company”)

DIVIDEND: TAX TREATMENT AND SALIENT DATES

Shareholders are referred to Dipula’s unaudited condensed consolidated interim results for the six months ended
28 February 2018, published on SENS on 21 May 2018, wherein shareholders were advised of gross dividends no.
14 of 52.67488 cents per A-share and 44.07594 cents per B-share for the six months ended 28 February 2018 (“the
dividends”).

In accordance with Dipula’s status as a REIT, shareholders are advised that the dividends meet the requirements of
a “qualifying distribution” for the purposes of section 25BB of the Income Tax Act, No. 58 of 1962 (“Income Tax
Act”) and 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 dividends are 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. 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 42.13990 cents per A-share and 35.26075 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 dividends are 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 dividends if such documents have not already
been submitted, if applicable.

The dividends are payable to Dipula shareholders in accordance with the timetable set out below:
                                                                                                              2018

Last date to trade cum dividend:                                                                   Tuesday, 5 June
Shares trade ex dividend:                                                                        Wednesday, 6 June
Record date:                                                                                        Friday, 8 June
Payment date:                                                                                      Monday, 11 June

Share certificates may not be dematerialised or rematerialised between Wednesday, 6 June 2018 and Friday, 8 June 2018, 
both days inclusive.

The dividend will be transferred to dematerialised shareholders’ CSDP accounts/broker accounts on Monday, 11 June 2018. 
Certificated shareholders’ dividend payments will be paid to certificated shareholders’ bank accounts on or about, Monday, 
11 June 2018.

A-shares in issue at the date of declaration of the dividends: 264 665 819
B-shares in issue at the date of declaration of the dividends: 264 665 819

Dipula’s income tax reference number: 9743/798/14/3

21 May 2018


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