Wrap Text
Cash dividend: Tax treatment and salient dates
VUKILE PROPERTY FUND LIMITED
(Incorporated in the Republic of South Africa)
(Registration number 2002/027194/06)
JSE share code: VKE NSX share code: VKN
ISIN: ZAE000180865
Debt company code: VKEI
(Granted REIT status with the JSE)
(“Vukile”)
CASH DIVIDEND: TAX TREATMENT AND SALIENT DATES
Shareholders are referred to Vukile’s unaudited condensed consolidated interim results for the six months
ended 30 September 2019, released on SENS on 2 December 2019, and in particular, the notification of a
gross cash dividend of 80.83610 cents per share for the six months ended 30 September 2019 (“the dividend”)
referred to therein, and are advised as follows.`
Vukile was granted REIT status by the JSE Limited with effect from 1 April 2013 in line with the REIT
structure as provided for in the Income Tax Act, 58 of 1962, as amended (the Income Tax Act) and section 13
of the JSE Listings Requirements.
The REIT structure is a tax regime that allows a REIT to deduct qualifying dividends paid to investors, in
determining its taxable income.
The cash dividend of 80.83610 cents per share meets the requirements of a “qualifying distribution” for the
purposes of section 25BB of the Income Tax Act (a qualifying distribution) with the result that:
- dividends received by South African resident Vukile shareholders must be included in the gross income
of such shareholders (as a non-exempt dividend in terms of section 10(1)(k)(i)(aa) of the Income Tax Act),
with the effect that the dividends are taxable as income in the hands of the Vukile shareholder. These
dividends are, however, exempt from dividends withholding tax, provided that the South African resident
shareholders 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 declaration that the distribution is exempt from dividends tax; and
- 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 distribution, if such documents have
not already been submitted.
- dividends received by non-resident Vukile shareholders will not be taxable as income and instead will be
treated as ordinary dividends but which are exempt in terms of the usual dividend exemptions per section
10(1)(k) of the Income Tax Act. It should be noted that dividends received by non-residents are subject to
dividends withholding tax 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. Assuming dividends withholding tax will be withheld at a rate of 20%, the net distribution
amount due to non-resident shareholders is 64.66888 cents per share. A reduced dividend withholding rate
in terms of the applicable DTA, may only be relied upon if the non-resident holder 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 declaration that the dividend is subject to a reduced rate as a result of the application of a DTA; and
- 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
holders 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 applicable.
Shareholders are further advised that:
- the issued capital of Vukile is 956 226 628 shares of no par value at 2 December 2019, being the
declaration date; and
- Vukile’s tax reference number is 9331/617/14/3.
The salient dates relating to the cash dividend are as follows:
Salient dates and times 2019
Last day to trade cum dividend Tuesday, 17 December
Shares trade ex dividend Wednesday, 18 December
Record date Friday, 20 December
Payment date Monday, 23 December
Notes:
1. Share certificates may not be dematerialised or rematerialised between Wednesday, 18 December 2019
and Friday, 20 December 2019, both days inclusive.
2. Payment of the dividend will be made to shareholders on Monday, 23 December 2019.
2 December 2019
Corporate advisor and JSE sponsor NSX sponsor
Java Capital IJG Securities
Date: 02-12-2019 07:45:00
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.