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Dividend: tax treatment and salient dates
ATTACQ LIMITED
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 "the company" or "the group")
DIVIDEND: TAX TREATMENT AND SALIENT DATES
Shareholders are referred to Attacq's condensed unaudited consolidated interim financial results for the six months ended
31 December 2023, published on SENS on 12 March 2024, wherein shareholders were advised of the interim gross dividend
of 30.00000 cents per share for the six months ended 31 December 2023 ("the dividend").
2024
Last day to trade cum dividend Tuesday, 2 April
Shares trade ex dividend Wednesday, 3 April
Record date Friday, 5 April
Payment date Monday, 8 April
Notes:
1. Share certificates may not be dematerialised or rematerialised between Wednesday, 3 April 2024 and Friday, 5
April 2024, both days inclusive.
2. Payment of the dividend will be made to shareholders on Monday, 8 April 2024. In respect of dematerialised
shareholders, the dividend will be transferred to the Central Securities Depository Participant ("CSDP") account
or broker account on Monday, 8 April 2024. Certificated shareholders' dividends will be deposited on or about
Monday, 8 April 2024.
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.
In accordance with Attacq's status as a Real Estate Investment Trust ("REIT"), shareholders are advised that the dividend
meets the requirements of a "qualifying 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 dividend, for South African tax purposes, in terms
of section 25BB of the Income Tax Act.
Tax implications for South African resident shareholders
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 South African tax resident shareholders provide 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 exempt from dividend tax
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
c) 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 before payment of the dividend, if such documents have not already
been submitted.
Tax implications for non-resident shareholders
Dividends received by non-resident shareholders will not be taxable as income and instead will be treated as ordinary
dividends 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
20.0%, 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. Assuming dividend withholding tax will be
withheld at a rate of 20.0%, the net dividend amount due to non-resident shareholders is 24.00000 cents per 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 dividend is subject to a reduced rate as a result of the application of a DTA
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
c) 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 above-mentioned documents to be submitted before payment of the dividend if such documents have not
already been submitted, if applicable.
The number of shares in issue on 31 December 2023 and the date of this announcement is 748 618 337 ordinary shares of
no par value, which includes 46 427 553 treasury shares. Attacq's tax reference number is 9241/038/64/6.
12 March 2024
Sponsor
Java Capital
Date: 12-03-2024 07:15:00
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