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Dividend: tax treatment and salient dates
FORTRESS REIT LIMITED
(Incorporated in the Republic of South Africa)
(Registration number 2009/016487/06)
JSE share codes: FFA ISIN: ZAE000248498
FFB ISIN: ZAE000248506
Bond company code: FORI
(Approved as a REIT by the JSE)
(“Fortress” or “the company”)
DIVIDEND: TAX TREATMENT AND SALIENT DATES
Shareholders are referred to Fortress’ provisional audited summarised consolidated financial statements for the year
ended 30 June 2019, published on SENS on 2 September 2019, wherein shareholders were advised of gross dividends
of 73,62000 cents per Fortress A ordinary share (“FFA”) and 78,01000 cents per Fortress B ordinary share (“FFB”)
share for the six months ended 30 June 2019 (“the dividends”).
In accordance with Fortress’ status as a REIT, shareholders are advised that the dividends meets the requirements of
a “qualifying distribution” for the purposes of section 25BB of the Income Tax Act, No. 58 of 1962 (“Income Tax
Act”). The dividends on the shares 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 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
58,89600 cents per FFA share and 62,40800 cents per FFB 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 dividends are payable to Fortress shareholders in accordance with the timetable set out below:
2019
Last date to trade cum dividend: Monday, 23 September
Shares trade ex dividend: Wednesday, 25 September
Record date: Friday, 27 September
Payment date: Monday, 30 September
Share certificates may not be dematerialised or rematerialised between Wednesday, 25 September 2019 and Friday,
27 September 2019, both days inclusive. Payment of the dividend will be made to shareholders on Monday,
30 September 2019. In respect of dematerialised shares, the dividend will be transferred to the CSDP accounts/broker
accounts on Monday, 30 September 2019. Certificated shareholders’ dividend payments will be deposited on or about
Monday, 30 September 2019.
A shares in issue at the date of declaration of the dividend: 1 189 915 138
B shares in issue at the date of declaration of the dividend: 1 091 532 994
Fortress’ income tax reference number: 9218846179
2 September 2019
Lead sponsor
Java Capital
Joint sponsor
Nedbank Corporate and Investment Banking
Date: 03/09/2019 07:06:00
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