Wrap Text
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 2019, published on SENS on 20 November 2019, wherein shareholders were advised
the final gross dividend (dividend number 17) for the period 1 March 2019 to 31 August 2019 of 55.41534
cents per A-share and 40.20377 cents per B-share.
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 44.33227 cents per A-share and 32.16302 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:
Last day to trade cum dividend Tuesday, 10 December 2019
Shares trade ex-dividend Wednesday, 11 December 2019
Record date Friday, 13 December 2019
Payment date Tuesday, 17 December 2019
Share certificates may not be dematerialised or rematerialised between Wednesday, 11 December 2019 and
Friday, 13 December 2019, both days inclusive. The dividend will be transferred to dematerialised
shareholders' CSDP accounts/broker accounts on Tuesday, 17 December 2019. Certificated shareholders'
dividend payments will be paid to certificated shareholders' bank accounts on or about Tuesday,
17 December 2019.
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.
20 November 2019
Sponsor
Java Capital
Date: 20/11/2019 09:01:00
Produced by the JSE SENS Department. The SENS service is an information dissemination service administered by the JSE Limited ('JSE').
The JSE does not, whether expressly, tacitly or implicitly, represent, warrant or in any way guarantee the truth, accuracy or completeness of
the information published on SENS. The JSE, their officers, employees and agents accept no liability for (or in respect of) any direct,
indirect, incidental or consequential loss or damage of any kind or nature, howsoever arising, from the use of SENS or the use of, or reliance on,
information disseminated through SENS.
Sharenet Sites 
