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DELTA PROPERTY FUND LIMITED - Tax implications

Release Date: 04/06/2018 07:40
Code(s): DLT     PDF:  
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Tax implications

DELTA PROPERTY FUND LIMITED
(Incorporated in the Republic of South Africa)
(Registration number 2002/005129/06)
Share code: DLT ISIN: ZAE000194049
(“Delta” or “the Fund” or “the Group”)
(REIT status approved)

Tax implications

Further to the reviewed provisional condensed consolidated financial results for the year ended 28
February 2018 released on SENS on 4 June 2018, set out below the tax implication for the dividend
payment of 50.84210 cents per share.

Tax implications for South African resident shareholders
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 Section 10(1)(k)(i)(aa) of the Income Tax Act because they are
dividends distributed by a REIT. These dividends are however exempt from dividend withholding tax
(“Dividend Tax”) in the hands of South African resident shareholders provided that the South African
resident shareholders have provided to the CSDP or broker, as the case may be, in respect of
uncertificated shares, or the transfer secretaries in respect of certificated shares:

-   a declaration that the distribution is exempt from Dividends Tax; and
-   a written undertaking to inform the CSDP, broker or the transfer secretaries, as the case may be,
    should the circumstances affecting the exemption change or the beneficial owner ceases to be
    the beneficial owner,

both in the form prescribed by the Commissioner for the South African Revenue Service. If resident
shareholders have not submitted the abovementioned documentation to confirm their status as a
South African resident, they are advised to contact their CSDP or broker, as the case may be, to arrange
for the documents to be submitted prior to the payment of the dividend.

Tax implications for non-resident shareholders
Dividends received by non-resident shareholders from a REIT will not be taxable as income and will be
exempt from income tax in terms of the exemption in section (10)(1)(k)(i) of the Income Tax Act. Any
dividend received by a non-resident from a REIT is subject to Dividend 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 non-resident shareholders. Assuming Dividend Tax
will be withheld at the current rate of 20%, the net dividend amount due to non-resident shareholders
is 40.67368 cents per share. A reduced Dividend Tax 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 transfer secretaries, in respect of
certificated shares:

-   a declaration that the dividend is subject to a reduced rate as a result of the application of a DTA;
    and
-   a written undertaking to inform the CSDP, broker or the transfer secretary, 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. If applicable,
non-resident shareholders are advised to contact their CSDP, broker or the transfer secretary, as the
case may be, to arrange for the abovementioned documents to be submitted prior to the payment of
the dividend if such documents have not already been submitted.

711 844 486 Delta shares are in issue at the date of this dividend declaration and Delta’s income tax
reference number is 9464252148.


4 June 2018

Sponsor: Nedbank Corporate and Investment Banking




                                                
Date: 04/06/2018 07:40:00 Produced by the JSE SENS Department. The SENS service is an information dissemination service administered by the JSE Limited ('JSE'). 
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