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Finalisation announcement in respect of the cash dividend for the six months ended 30 June 2019
EPP N.V.
(Incorporated in The Netherlands)
(Company number 64965945)
JSE share code: EPP
ISIN: NL0011983374
LEI Code: 7245003P7O9N5BN8C098
(“EPP” or “the company”)
FINALISATION ANNOUNCEMENT IN RESPECT OF THE CASH DIVIDEND FOR THE SIX MONTHS ENDED 30 JUNE 2019
Shareholders are referred to the dividend declaration announcement released on SENS and published on the
Luxembourg Stock Exchange website on 6 September 2019 (the “declaration announcement”) and are
advised that shareholders on the South African share register will receive their cash dividend in ZAR, converted
from Euro at an exchange rate of EUR1.00:ZAR16.26839. Accordingly, the cash dividend of 5.80000 euro
cents per share will be equal to a gross local dividend amount for shareholders on the South African register of
ZAR94.35666 cents per share. The currency exchange is based on an average rate achieved by means of a
series of hedges, with a settlement date of 4 October 2019. The exchange rate was derived from the intraday
spot as reflected by Reuters D3 for each particular hedge.
Shareholders are referred to the Dutch and South African tax implications in respect of receipt of the cash
dividend by EPP shareholders set out in the declaration announcement and are requested to submit the required
documentation to EPP and/or their CSDP within the prescribed time periods in order to take advantage of any
reduction, rebate or exemption from dividends withholding tax for which they qualify.
As a general rule, 15% Dutch dividend withholding tax (“DWHT”) will be withheld by EPP on the cash
dividend, leaving a distribution amount per share net of Dutch DWHT of ZAR80.20316 cents per share. This
could be different if:
- a shareholder qualifies for an exemption from or a reduction of Dutch DWHT on the basis of Dutch
domestic law and/or a tax treaty concluded by the Netherlands; and
- the formal requirements to apply such exemption from or reduction of Dutch DWHT are satisfied (insofar
applicable).
EPP will initially withhold 15% on ALL dividends distributed on Monday, 7 October 2019.
Cash dividends received from a foreign (non-resident) company in respect of a share that is listed on the JSE
are regarded as foreign dividends for South African income tax and dividends withholding tax purposes.
As a general rule, 20% South African dividends withholding tax (“SADWT”) will be withheld by the regulated
intermediary in South Africa (CSDP) on the cash dividend, leaving a distribution amount per share net of
SADWT. This could be different if:
- a shareholder qualifies for an exemption from SADWT on the basis of South African domestic law; and
- the formal requirements to apply such exemption from SADWT are satisfied (insofar applicable).
Where a CSDP is satisfied that a particular shareholder has correctly suffered 15% DWHT which is not
recoverable by that shareholder from the Dutch tax authority, such CSDP should withhold 5% SADWT (being
the 20% SADWT less 15% DWHT) (leaving a distribution amount per share net of DWHT and SADWT of
ZAR75.48533 cents per share), unless a specific South African domestic exemption applies and the required
documentation has been provided to the CSDP.
The information provided above does not constitute tax advice and is only provided as a general guide on the
South African tax treatment of the cash dividend declaration by EPP to South African tax resident shareholders.
For shareholders residing outside of South Africa, the dividend may have other legal or tax implications and
such shareholders are advised to obtain appropriate advice from their professional advisers in this regard.
23 September 2019
JSE Sponsor
Java Capital
Luxembourg Stock Exchange Listing Agent
Harneys Luxembourg
For more information:
Curwin Rittles, Investor Relations, EPP
Mobile: +48 885 982 310
Curwin.rittles@epp-poland.com
Java Capital, JSE Sponsor
Phone: +27 11 722 3050
Harneys Luxembourg, Luxembourg Stock Exchange Listing Agent
Phone: +352 27 86 71 02
Singular Systems IR
Michèle Mackey / Jacques de Bie
+27 (0)10 003 0700/+27 (0)82 497 9827
michele@singular.co.za / Jdebie@singular.co.za
Date: 23/09/2019 08:00:00
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