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HAMMERSON PLC - Dividend Currency Conversion announcement - Dividend no. 136

Release Date: 05/03/2019 11:02
Code(s): HMN     PDF:  
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Dividend Currency Conversion announcement - Dividend no. 136

Hammerson plc
(Incorporated in England and Wales)
(Company number 360632)
LSE share code: HMSO JSE share code: HMN
ISIN: GB0004065016
(“Hammerson” or “the Company”)

Dividend Currency Conversion Announcement - Dividend No. 136

5 March 2019

On 25 February 2019, the Board of Directors of the Company proposed a final dividend of
GBP 14.8 pence per share for the period ended 31 December 2018 (“the Dividend”),
subject to approval by the shareholders of the Company at the Annual General Meeting to
be held on Tuesday, 30 April 2019.

The Dividend will be subject to a 20% UK withholding tax unless exemptions apply. GBP 7.4
pence will be treated as a Property Income Distribution (“PID”), net of withholding tax
where appropriate, and GBP 7.4 pence will be paid as a normal dividend (“Non-PID”).

The Company will not be offering a scrip dividend alternative, but for shareholders who wish
to receive their dividend in the form of shares, the Dividend Reinvestment Plan (“DRIP”) will
be available.

The Dividend is payable on Thursday, 2 May 2019 to shareholders registered on the UK
principal register (“UK Shareholders”) and the South African branch register (“SA
Shareholders”) who have elected to receive the Dividend in cash. The Record Date for
both UK Shareholders and SA Shareholders is at the close of business on Friday, 22 March
2019. The DRIP purchases settlement date (subject to market conditions and the purchase
of shares in the open market) is Tuesday, 7 May 2019.

The Dividend should be regarded as a “foreign dividend” for SA income and SA dividend
tax purposes.

Shareholders receiving the Dividend in cash

The Company confirms that the South African Rand exchange rate for the Dividend will be
ZAR 18.89640 to GBP 1. The Dividend is payable in South African Rand to SA Shareholders.
Shareholders who do not elect the DRIP will be paid as follows:

PID                                            UK Shareholders            SA Shareholders

                                                   (GBP pence)                 (ZAR cents)

Gross amount of PID                                        7.40                 139.83336

Less 20% UK withholding tax/20% SA                         1.48                  27.96667
dividends tax

Net PID dividend payable*                                  5.92                 111.86669

Less 5% SA Shareholders excess                             n/a                    6.99167
reclaim

Net PID dividend payable**                                 n/a                  104.87502

*Net position after SA Shareholders have claimed back 5% from HMRC under the double tax
agreement between the United Kingdom and South Africa.

** Before SA shareholders have claimed back 5% from HMRC under the double tax
agreement between the United Kingdom and South Africa.

                                               UK Shareholders           SA Shareholders
Non-PID*
                                                  (GBP pence)                 (ZAR cents)

Gross amount of Non-PID                                    7.40                 139.83336

Less 20% SA dividends tax                                  n/a                   27.96667

Net Non-PID dividend payable                               7.40                 111.86669

*Non-PID – taxed as a normal dividend

Cash PIDs

A 20% UK withholding tax will be deducted from cash PIDs. The Company will account to
Her Majesty’s Revenue & Customs (“HMRC”) in sterling for the total UK withholding tax
deducted.

SA dividends tax, at the rate of 20%, will apply to cash PIDs payable by the Company unless
the beneficial owner of the Dividend is exempt from SA dividends tax (e.g. if it is a South
African resident company). Under the double tax agreement between the UK and South
Africa (“the DTA”), the maximum tax payable in the UK is 15%. South African resident
shareholders are therefore entitled to claim the excess of 5% from HMRC. As SA
Shareholders are entitled to reclaim this excess from HMRC, the maximum rebate allowable
in respect of the UK withholding tax against the SA dividends tax is 15%, which means that
the Company will have to withhold a further 5% from the Dividend in South Africa to bring
the total dividends tax to 20%. In summary, therefore, 20% will be withheld in the UK, a
further 5% will be withheld in South Africa (where appropriate), but South African resident
shareholders will be entitled to claim back 5% from HMRC, which will bring the overall total
to 20%.
Cash Non-PIDs

SA dividends tax at the rate of 20% will apply to cash Non-PIDs paid by the Company, unless
the beneficial owner of the Dividend is exempt from SA dividends tax (e.g. if the beneficial
owner is a South African company or a non-South African resident). Since no withholding
tax is suffered in the UK on cash Non-PIDs, no rebate can be claimed. The relevant
regulated intermediary (being the SA transfer secretaries or other CSDP, broker or institution,
as applicable) will therefore be required to deduct 20% tax on all cash Non-PID’s paid to
persons who are not exempt from SA dividends tax, and pay this to the South African
Revenue Service.

Shareholders electing the DRIP

SA Shareholders electing the DRIP should note that, in respect of fractional entitlements that
may arise, all allocations of shares will be rounded down to the nearest whole number, and
any residual amounts that are not used to reinvest in shares (as a result of rounding down)
will be paid out to these SA Shareholders in cash.

It is the Company’s understanding that the residual cash paid to SA Shareholders who have
made DRIP elections would already have been taxed prior to the calculation of the number
of shares and any residual cash owing to such SA Shareholders. Accordingly, no further tax
should be payable on the cash paid to SA Shareholders as a result of any fractional
entitlements.

The above information and the guidelines on the taxation of dividends are provided as a
general guide based on the Company’s understanding of the law and practice currently in
place. Any shareholder who is in any doubt as to their tax position should seek
independent professional advice.

Registered Office     UK Registrars             SA Transfer Secretaries
Kings Place           Link Asset Services       Computershare Investor
90 York Way           The Registry              Services Proprietary Limited
London                34 Beckenham Road         Computershare Investor
N1 9GE                Beckenham                 Services Proprietary Limited
United Kingdom        Kent                      (Registration number
                      BR3 4TU                   2004/003647/07)
                      United Kingdom            1st Floor, Rosebank Towers
                                                15 Biermann Avenue,
                                                Rosebank, 2196
                                                South Africa
                                                (PO Box 61051,
                                                Marshalltown, 2107 South Africa)

For further information contact:

Julia Crane
Deputy Company Secretary
Tel: +44 (0)20 7887 1000
Hammerson has its primary listing on the London Stock Exchange and a secondary
inward listing on the Johannesburg Stock Exchange.

Sponsor:
Investec Bank Limited

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