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Dividend: tax treatment and salient dates
HYPROP INVESTMENTS LIMITED
(Incorporated in the Republic of South Africa)
(Registration number 1987/005284/06)
JSE share code: HYP ISIN: ZAE000190724
(Approved as a REIT by the JSE)
(“Hyprop” or the “company”)
DIVIDEND: TAX TREATMENT AND SALIENT DATES
Shareholders are referred to Hyprop’s summarised consolidated audited results for the year ended
30 June 2019, published on SENS on Thursday, 5 September 2019, and in particular, the notification of a gross
dividend of 359.33956 cents per Hyprop share (“the dividend”) referred to therein, and are advised as follows:
In accordance with Hyprop’s status as a 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, 58 of 1962
(“Income Tax Act”). The distribution 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.
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 they are
dividends distributed by a REIT. The dividend is, 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 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. 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 287.47165 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; 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 dividend if such documents have not
already been submitted, if applicable.
The dividend is payable to Hyprop shareholders in accordance with the timetable set out below:
Last date to trade cum dividend: Tuesday, 8 October 2019
Shares trade ex dividend: Wednesday, 9 October 2019
Record date: Friday, 11 October 2019
Payment date: Monday, 14 October 2019
Share certificates may not be dematerialised or rematerialised between Wednesday, 9 October 2019 and
Friday, 11 October 2019, both days inclusive. Payment of the dividend will be made to shareholders on
Monday, 14 October 2019. In respect of dematerialised shares, the dividend will be transferred to the CSDP
accounts/broker accounts on Monday, 14 October 2019. Certificated shareholders’ dividend payments will be
deposited on or about Monday, 14 October 2019.
Shares in issue at the date of declaration of the dividend: 255 894 516
Hyprop’s income tax reference number: 9425177715
5 September 2019
Sponsor
Java Capital
Date: 05/09/2019 07:06:00
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