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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 unaudited condensed consolidated interim results for the six months ended
28 February 2022, published on SENS on 5 May 2022, wherein shareholders were advised that the board approved an
interim gross dividend (dividend number 20) for the period 1 September 2021 to 28 February 2022 of 61.97130 cents
per A share and 42.21706 per B share.
The dividend is payable to Dipula shareholders in accordance with the timetable set out below:
Last day to trade cum dividend Tuesday, 31 May 2022
Shares trade ex-dividend Wednesday, 1 June 2022
Record date Friday, 3 June 2022
Payment date Monday, 6 June 2022
Share certificates may not be dematerialised or rematerialised between Wednesday, 1 June 2022 and Friday,3 June 2022,
both days inclusive. The dividend will be transferred to dematerialised shareholders' CSDP accounts/broker accounts
on Monday, 6 June 2022. Certificated shareholders' dividend payments will be paid to certificated shareholders' bank
accounts on or about Monday, 6 June 2022.
TAX TREATMENT
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 49.57704 cents per A share and
33.77365 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.
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.
The dividend may have tax implications for resident as well as non-resident shareholders. Shareholders are therefore
encouraged to consult their professional advisors should they be in any doubt as to the appropriate action to take.
5 May 2022
Sponsor
Java Capital
Date: 05-05-2022 08:02:00
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