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 Produced by the JSE SENS Department. The SENS service is an information dissemination service administered by the JSE Limited ('JSE'). The JSE does not, whether expressly, tacitly or implicitly, represent, warrant or in any way guarantee the truth, accuracy or completeness of the information published on SENS. The JSE, their officers, employees and agents accept no liability for (or in respect of) any direct, indirect, incidental or consequential loss or damage of any kind or nature, howsoever arising, from the use of SENS or the use of, or reliance on, information disseminated through SENS.