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Dividend: Tax treatment and salient dates
ATTACQ LIMITED
Incorporated in the Republic of South Africa
Registration number 1997/000543/06
JSE share code: ATT
A2X share code: ATTJ
JSE alpha code: ATTI
ISIN: ZAE000177218
(Approved as a REIT by the JSE)
(Attacq or "the company" or "the group")
DIVIDEND: TAX TREATMENT AND SALIENT DATES
Shareholders are referred to Attacq's unaudited consolidated interim financial results for the six months ended
31 December 2024, published on SENS on 11 March 2025, wherein shareholders were advised of the interim
gross cash dividend of 44.00000 cents per share for the six months ended 31 December 2024 ("the dividend"),
out of the company's distributable income.
The dividend is payable to Attacq shareholders in accordance with the timetable set out below:
2025
Last day to trade cum dividend Tuesday, 1 April
Shares trade ex dividend Wednesday, 2 April
Record date Friday, 4 April
Payment date Monday, 7 April
Notes:
1. Share certificates may not be dematerialised or rematerialised between Wednesday, 2 April 2025 and
Friday, 4 April 2025, both days inclusive.
2. Payment of the dividend will be made to shareholders on Monday, 7 April 2025. In respect of
dematerialised shareholders, the dividend will be transferred to the Central Securities Depository
Participant ("CSDP") account or broker account on Monday, 7 April 2025. Certificated shareholders'
dividends will be deposited on or about Monday, 7 April 2025.
3. Where the transfer secretaries do not have the banking details of any certificated shareholders, the
cash dividend will be held in trust by the transfer secretaries pending receipt of the relevant
certificated shareholder's banking details whereafter the cash dividend will be paid via electronic
transfer into the personal bank accounts of certificated shareholders.
In accordance with Attacq's status as a Real Estate Investment Trust ("REIT"), shareholders are advised that
the dividend 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 dividend on the shares will be deemed to be a
dividend, for South African tax purposes, in terms of section 25BB of the Income Tax Act.
Tax implications for South African resident shareholders
The dividend 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 it is a dividend
distributed by a REIT. This dividend is, however, exempt from dividend withholding tax (dividend tax) in the
hands of South African tax resident shareholders, provided that South African tax resident shareholders
provide 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 exempt from dividend 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 before payment of the dividend, if such documents have not
already been submitted.
Tax implications for non-resident shareholders
Dividends received by non-resident shareholders will not be taxable as income and instead will be treated as
ordinary dividends 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 20.0%, 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 20.0%, the net dividend amount
due to non-resident shareholders is 35.20000 cents per 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 above-mentioned documents to be submitted before payment of the dividend if such documents have
not already been submitted, if applicable.
The number of shares in issue on 31 December 2024 and at the date of this announcement is 746 198 337
ordinary shares of no par value, which includes 46 427 553 treasury shares. Attacq's tax reference number is
9241/038/64/6.
11 March 2025
Equity sponsor Debt sponsor
Java Capital Nedbank Corporate and Investment Banking,
(a division of Nedbank Limited)
Date: 11-03-2025 07:06:00
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