Dividend: Tax treatment and salient dates
(Incorporated in the Republic of South Africa)
(Registration number 1997/000543/06)
JSE share code: ATT ISIN: ZAE000177218
(Approved as a REIT by the JSE)
("Attacq" or "Company")
DIVIDEND: TAX TREATMENT AND SALIENT DATES
Shareholders are referred to Attacq's summarised provisional consolidated financial results for the year ended 30
June 2019, published on SENS on 10 September 2019, wherein shareholders were advised of the final gross dividend
of 41.00000 cents per share for the six months ended 30 June 2019 ("the dividend").
In accordance with Attacq's status as a REIT with effect from 29 March 2018, shareholders are advised that the
dividend meets the requirements of a "distribution" for the purposes of section 25BB of the Income Tax
Act, No. 58 of 1962 ("Income Tax Act"). The dividend on the shares will be deemed to be a taxable 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 (dividend tax) in the hands of South African
tax resident shareholders, provided that the South African tax resident 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 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 20.0% (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
32.80000 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 dividend 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
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 dividend if such documents have not already been submitted, if
The dividend is payable to Attacq shareholders in accordance with the timetable set out below:
Last date to trade cum dividend: Tuesday, 1 October
Shares trade ex dividend: Wednesday, 2 October
Record date: Friday, 4 October
Payment date: Monday, 7 October
1. Shares certificates may not be dematerialised or rematerialised between Wednesday, 2 October 2019 and
Friday, 4 October 2019, both days inclusive.
2. Payment of the dividend will be made to shareholders on Monday, 7 October 2019. In respect of
dematerialised shareholders, the dividend will be transferred to the Central Securities Depository
Participant (CSCP) account or broker account on Monday, 7 October 2019. Certificated shareholder dividend will be
deposited on or about Monday, 7 October 2019.
3. Where the transfer secretaries do not have the banking details of any certificated shareholders, the cash
dividend will be held in trust by the transfer secretaries pending receipt of the relevant certificated
shareholder's banking details whereafter the cash dividend will be paid via electronic transfer into the
personal bank accounts of certificated shareholders.
The number of shares in issue as at 30 June 2019 and as at the date of this announcement is 749 922 777 ordinary
shares of no par value which includes 46 427 553 treasury shares. Attacq's tax reference number is 9241/038/64/6.
10 September 2019
Date: 10/09/2019 07:31:00
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