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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 reviewed provisional condensed consolidated financial results for the year
ended 31 August 2018, published on SENS today, Monday, 19 November 2018, wherein shareholders were
advised of gross final dividend (dividend number 15) of 53.13072 cents per A-share and 55.60278 cents per B-
share for the period 1 March 2018 to 31 August 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 42.50458 cents per A share and 44.48222 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, 4 December
Shares trade ex dividend: Wednesday, 5 December
Record date: Friday, 7 December
Payment date: Monday, 10 December
Share certificates may not be dematerialised or rematerialised between Wednesday, 5 December 2018 and
Friday, 7 December 2018, both days inclusive.
The dividend will be transferred to dematerialised shareholders' CSDP accounts/broker accounts on
Monday, 10 December 2018. Certificated shareholders’ dividend payments will be paid to certificated
shareholders’ bank accounts on or about Monday, 10 December 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
19 November 2018
Sponsor
Java Capital
Date: 19/11/2018 10:01:00 Produced by the JSE SENS Department. The SENS service is an information dissemination service administered by the JSE Limited ('JSE').
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