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Acucap -- Dividend finalisation
Acucap shareholders are referred to the dividend declaration announcement released on SENS on 1 April 2015 (the “Declaration Date”) and are hereby given notice that a dividend of 172.63 cents per share has been approved in respect of the period 1 October 2014 to 31 March 2015 (the “Dividend”). The last day to trade Acucap shares cum-dividend is Friday, 17 April 2015 and the record date in respect of the Dividend is Friday, 24 April 2015. Acucap shares will start trading ex-dividend from Monday, 20 April 2015 and the Dividend payment will be made to Acucap shareholders on Tuesday, 28 April 2015.
Acucap share certificates may not be dematerialised or rematerialised between Monday, 20 April 2015 and Friday, 24 April 2015, both days inclusive.
As of the Declaration Date, Acucap has 241 002 184 shares of no par value in issue.
Tax treatment of the dividend
The information in this announcement is provided as a general guide to the potential South African tax consequences pertaining to the Dividend for Acucap shareholders that are subject to South African tax. The information provided in this announcement is not intended as comprehensive tax advice, nor does it purport to take into account all of the considerations that may be relevant to shareholders in relation to the Dividend. Acucap shareholders should consult their tax advisors for advice on the particular tax consequences applicable to them.
In accordance with Acucap’s status as a REIT, Acucap shareholders are hereby advised that the Dividend will meet the requirements of a ‘qualifying distribution’ for the purposes of section 25BB of the Income Tax Act, No.58 of 1962 (the “Income Tax Act”). The Dividend will therefore be deemed to be a dividend for South African tax purposes, in terms of section 25BB of the Income Tax Act.
Tax implications for shareholders who are South African tax residents
The Dividend received by or accrued to a shareholder who is a South African tax resident must be included in the gross income of such shareholder. The Dividend will not be exempt from income tax in terms of the general dividend exemption contained in paragraph (aa) of section 10(1)(k)(i) of the Income Tax Act due to the fact that it is a dividend distributed by a REIT. The Dividend may however be exempt from dividend withholding tax, in which case the net dividend amount will be equal to the gross dividend amount disclosed above provided that the shareholder has submitted the following documents in the manner detailed below:
- a declaration that the Dividend is exempt from dividends tax; and
- a written undertaking to inform the CSDP, broker or, in respect of certificated shareholders only, Computershare, should the circumstances affecting the exemption change or the beneficial owner cease to be the beneficial owner, in the form prescribed by the Commissioner for the South African Revenue Service.
Tax implication for non-resident shareholders
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. From 1 January 2014, any dividend received by a non-resident from a REIT is subject to dividend withholding tax at 15% in which case the net Dividend amount will be 146.73550 cents per Acucap share, unless the rate is reduced in terms of any applicable Double Taxation Agreement (‘DTA’) between South Africa and the country of residence of the shareholder.
A reduced dividend tax withholding rate in terms of the applicable DTA may only be relied upon if the non-resident shareholder has provided the following documents in the manner detailed below:
- 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 its CSDP, broker or Computershare, as the case may be, should the circumstances affecting the reduced rate change or the beneficial owner cease to be the beneficial owner, in the form prescribed by the Commissioner for the South African Revenue Service.
Submissions
The documents detailed above are required to be submitted as described below.
Dematerialised Acucap shareholders
- Dematerialised Acucap shareholders who have not already submitted the above- mentioned documents are advised to contact their CSDP or broker as the case may be, to arrange for the submission of the documents prior to payment of the Dividend.
Certificated Acucap shareholders
- Certificated Acucap shareholders, who have not already submitted the above- mentioned documents, may submit these documents to Computershare.
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