VUKILE REAL ESTATE FUND LIMITED (Incorporated in the Republic of South Africa) (registration number 2002/027194/06)

JSE share code: VKE NSX share code: VKN

ISIN: ZAE000180865

Bond company code: VKEI (Granted REIT status with the JSE) (“Vukile” Where “the company“)

DIVIDEND DECLARATION: TAX TREATMENT AND SIGNIFICANT DATES

Notice is hereby given that a gross cash dividend of 65.28653 cents per share has been declared from income reserves in respect of the year ended March 31, 2022. In accordance with Vukile’s status as a REIT , shareholders are advised that the distribution meets the requirements of a qualifying distribution for the purposes of Section 25BB of the Income Tax Act, 58 of 1962 (the “income tax lawThe distribution on the shares will be treated as a dividend for South African tax purposes under Section 25BB of the Income Tax Act.

Accordingly, the dividend received by South African tax residents must be included in their gross income and will not be exempt under the ordinary dividend exemption provided for in Article 10(1)(k)(i) of income tax law, as a consequence of subparagraph (aa) of the proviso which provides that dividends distributed by a REIT are not exempt from income tax.

The dividend is however exempt from withholding tax on dividends in the hands of South African tax resident shareholders, provided that South African resident shareholders provide the following forms to their participating central securities depository (“PSDC“) or broker, as the case may be for uncertificated shares or the company, for certificated shares:

  1. a statement that the dividends are exempt from dividend tax; and
  2. a written undertaking to inform the CSDP or the broker, as the case may be, if the circumstances affecting the change in the reduced rate or if the beneficial owner ceases to be the beneficial owner,

both in the form prescribed by the South African Revenue Commissioner. Shareholders are advised to contact their CSDP or broker, as the case may be, to have the above-mentioned documents delivered prior to payment of the distribution if such documents have not already been delivered.

Dividends received by non-resident shareholders will be exempt from income tax under Section 10(1)(k)(i) of the Income Tax Act. The rate of withholding tax on dividends is 20%, therefore any dividend will be subject to dividend withholding tax levied at a rate of 20%, unless the rate is reduced under any applicable agreement to avoid double taxation (“DTA“) between South Africa and the shareholder’s country of residence.

If dividend withholding tax is withheld at a rate of 20%, the net amount of dividend due to non-resident shareholders is 52.22922 cents per share. A reduced rate of withholding tax with respect to the applicable CDI can only be claimed if the non-resident shareholder has provided the following forms to his CSDP or his broker, as the case may be for dematerialized shares or to the company , for certificated shares:

  1. a statement that the dividend is subject to a reduced rate due to the application of a CDI; and
  1. a written undertaking to inform the CSDP or the broker, as the case may be, if the circumstances affecting the change in the reduced rate or if the beneficial owner ceases to be the beneficial owner,

both in the form prescribed by the South African Revenue Commissioner. Non-Resident Shareholders are advised to contact their CSDP or broker, as the case may be, to have the above documents delivered prior to payment of the distribution if such documents have not already been delivered.

The dividend is payable to Vukile shareholders according to the schedule below:

2022

Last day to trade sperm distribution of dividends:

tuesday 28

June 2022

Stock trading ex distribution of dividends:

wednesday 29

June 2022

Registration Date :

friday 1

July 2022

Payment date:

Monday, 4

July 2022

Share certificates cannot be dematerialized or rematerialized between Wednesday June 29, 2022 and Friday July 1, 2022 inclusive. The dividend will be paid to shareholders’ dematerialized CSDP accounts or broker accounts on Monday, July 4, 2022. Dividend payments from certificated shareholders will be paid to certificated shareholders’ bank accounts on or about Monday, July 4, 2022.

Shares outstanding on the date of declaration: 980,226,628.

Vukile Income Tax Reference Number: 9331/617/14/3.

June 9, 2022

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