Dividend: Tax Treatment and Salient Dates
HYPROP INVESTMENTS LIMITED
(Incorporated in the Republic of South Africa)
(Registration number 1987/005284/06)
JSE share code: HYP ISIN: ZAE000190724
(Approved as a REIT by the JSE)
("Hyprop" or "the company")
DIVIDEND: TAX TREATMENT AND SALIENT DATES
Shareholders are referred to Hyprop's summarised consolidated results for the year ended 30 June 2018, released on
SENS on 31 August 2018, and in particular, the notification of a gross dividend payment of 380.24450 cents per share
("the dividend") referred to therein, and are advised as follows:
In accordance with Hyprop'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 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. Assuming dividend withholding tax will be withheld at a rate of 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), the net dividend amount due to non-resident shareholders is 304.19560 cents per
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 dividend is payable to Hyprop’s shareholders in accordance with the timetable set out below:
Last day to trade cum dividend Tuesday, 25 September
Shares trade ex dividend Wednesday, 26 September
Record date Friday, 28 September
Payment date Monday, 1 October
Shareholders may not dematerialise or rematerialise their shares between Wednesday, 26 September 2018 and
Friday, 28 September 2018, both days inclusive. Payment of the dividend will be made to shareholders on
Monday, 1 October 2018. In respect of dematerialised shareholders, the dividend will be transferred to the CSDP
accounts/broker accounts on Monday, 1 October 2018. Certificated shareholders' dividend payments will be deposited
on or about Monday, 1 October 2018.
Shares in issue at the date of declaration of dividend: 255 894 516.
Hyprop's income tax reference number: 9425177715.
31 August 2018
Date: 31/08/2018 08:01:00 Produced by the JSE SENS Department. The SENS service is an information dissemination service administered by the JSE Limited ('JSE').
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