VUNANI LIMITED - Vunani Unbundling of VCP Shares: Apportionment of tax costs for South African Tax purposes

Vunani Unbundling of VCP Shares: Apportionment of tax costs for South African Tax purposes

VUNANI LIMITED
(Incorporated in the Republic of South Africa)
(Registration number 1997/020641/06)
JSE code: VUN
ISIN: ZAE000163382
(“Vunani”)

VUNANI UNBUNDLING OF VCP SHARES: APPORTIONMENT OF TAX COST FOR SOUTH AFRICAN TAX
PURPOSES

1. Introduction

Shareholders (“Shareholders”) are referred to the circular (“Circular”) posted on Monday,
30 November 2020 in respect of the VCP Unbundling from which the defined terms as utilised
below have been extracted from, unless specified otherwise.

Shareholders are further referred to the finalisation announcement released on SENS on 1
February 2020 confirming that the conditions precedent to the implementation of the VCP
Unbundling had been met and that implementation will occur in accordance with the
announced timeline.

Shareholders are reminded that the VCP Unbundling will be executed by Vunani using a
distribution ratio of 1:1 meaning that for every 1 Vunani Share held on the VCP Unbundling
Record Date, a Shareholder will receive 1 VCP Share.

2. Purpose of the announcement

The purpose of this announcement is to advise Vunani shareholders of the ratio in which
the expenditure incurred and / or the market value (for purposes of paragraph 29 of the
Eighth Schedule to the Income Tax Act) ("Market Value") in respect of the Vunani Shares
must be apportioned between the Vunani Shares and the unbundled VCP Shares for South
African taxation purposes ("Apportionment Ratio").

5. Apportionment Ratio calculation

Vunani shareholders are hereby advised that the Apportionment Ratio is based on the
closing price of 250 cents per Vunani Share on Wednesday, 10 February 2021 and 80.47 cents
per VCP Share, which value represents the Market Value of VCP.

The Apportionment Ratio applicable to the VCP Shares has therefore been calculated as
follows:

Apportionment Ratio = (A /(A + B))
Where –
A = the calculated price of a VCP Share x the unbundling ratio of 1:1, i.e. ZAR0.8047
(being ZAR 0.8047 x 1.0);
B = the closing price of a Vunani Share, i.e. ZAR2.50
= (ZAR0.8047/ (ZAR0.8047 + ZAR2.50))
= 24.35%

Shareholders are hereby advised that the expenditure incurred and/or Market Value, as the
case may be, in respect of Vunani Shares must therefore be apportioned in the ratio of
24.35% to a VCP Share and 75.65% to a Vunani Share.

Sandton
10 February 2021

Corporate Adviser
Vunani Corporate Finance

Sponsor
Grindrod Bank Limited

Date: 10-02-2021 05:31:00
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