27 Oct - 6 min read
Interim distribution Irongate Group (JSE: IAP) Comprising Irongate Property Fund I (IPF I, ARSN 162 067 736) and Irongate Property Fund II (IPF II, ARSN 644 081 309), established in Australia and registered with ASIC as managed investment schemes Operated by Irongate Funds Management Limited (ACN 071 514 246; AFSL 290 909) (Responsible Entity) IPF I is registered as a foreign collective investment scheme in terms of the Collective Investment Schemes Control Act No.45 of 2002 ISIN: AU0000046005 (IAP or the Fund) SENS ANNOUNCEMENT 27 October 2021 Interim distribution Notice is hereby given of an interim distribution for the six months ended 30 September 2021, declaration number 17, of: - 4.52860 AUD cents per stapled security pre withholding tax (WHT) - 4.10262 AUD cents per stapled security post WHT Tax of 0.42598 AUD cents per stapled security (being 9.40653% per stapled security) will be withheld from the interim distribution paid to non-Australian securityholders holding stapled securities on the Fund’s South African sub register. Amounts will also be withheld from non- Australian securityholders holding stapled securities on the Fund’s Australian sub register. The salient events and dates relating to the interim distribution are as follows (all times and dates are Johannesburg time, unless otherwise indicated): Event 2021 Declaration date Wednesday, 27 October Cross border movement of stapled securities between the Monday, 15 November Fund’s South African sub register and the Fund’s Australian sub register ceases at the close of business in South Africa or Australia (as applicable) Announce AUD into ZAR currency conversion rate(1) for Monday, 15 November payment of the interim distribution to securityholders on the Fund’s South African sub register, by 11h00 Last day to trade cum distribution on the JSE(2) Tuesday, 16 November Stapled securities trade ex-distribution on the JSE Wednesday, 17 November Last day to trade cum distribution on the ASX Wednesday, 17 November (Sydney time) Stapled securities trade ex-distribution on the ASX Thursday, 18 November (Sydney time) Record date Friday, 19 November Cross border movements of stapled securities between Monday, 22 November the Fund’s South African sub register and the Fund’s Australian sub register recommences Payment of interim distribution Friday, 3 December Footnotes: (1). Exchange rate calculated on Monday, 15 November 2021 (for release on SENS by 11h00). (2). Stapled securities may not be dematerialised or rematerialised between commencement of trade on the JSE on Wednesday, 17 November 2021 and close of trade on Friday, 19 November 2021, both dates inclusive. Fund payment amount applicable to the interim distribution for the six months ended 30 September 2021 This information is only applicable to foreign securityholders and other entities that are obliged to withhold tax on payments made to foreign residents. Australian-based securityholders should rely on tax statements that are due to be mailed by Thursday, 30 June 2022. For completeness, tax will be deducted from payments made to an Australian resident where the Australian securityholder does not provide an Australian business number or tax file number. The interim distribution includes a fund payment amount of 0.42598 AUD cents per stapled security. The fund payment has been determined in accordance with Subdivision 12A-B of Schedule 1 to the Taxation Administration Act 1953, being the amount from which an amount would have been required to be withheld under Subdivision 12-H of Schedule 1 to the Taxation Administration Act 1953 if the payment had been made to an entity covered by section 12-410 of Schedule 1 to the Taxation Administration Act 1953. The fund payment relates to the six months ended 30 September 2021. The Fund declares that IPF I is an Attribution Managed Investment Trust for the purposes of Subdivision 12-H of Schedule 1 of the Taxation Administration Act 1953 in respect of the income year ended 31 March 2022. Distribution information for the half year ended 30 September 2021 This information is only applicable to foreign securityholders and other entities that are obliged to withhold tax on payments made to foreign residents. The interim distribution is being made from IPF I. There is no distribution component from IPF II. Breakdown of the Total cash Component Component New distribution components distribution subject to subject to Zealand for the half year ended 30 fund other non- sourced September 2021(3) payment resident Income withholding withholding Net rental income 2.76321 2.76321 - - Capital gains - - - - Total fund payment (incl 2.76321 2.76321 - - capital gains) Interest income 0.11503 - 0.11503 - Foreign income(4) 0.42788 - - 0.42788 Non-assessable amount 1.22248 - - - Total distribution 4.52860 2.76321 0.11503 0.42788 Foreign tax paid - - - - (3). All amounts shown as AUD cents per stapled security. (4). The foreign income component of the distribution is subject to New Zealand corporate tax. General securityholder tax information for securityholders holding stapled securities on the Fund’s South African sub register IPF I and its management arrangements are structured to meet the required criteria to be classified as an Attribution Managed Investment Trust for Australian tax purposes. As an Attribution Managed Investment Trust, the Responsible Entity will be required to withhold tax on Australian sourced income at a concessional rate of 15% on fund payments (or 10% for certain fund payments from a Clean Building MIT) to individual and institutional securityholders in South Africa and certain other jurisdictions with an exchange of information (EOI) agreement with Australia. Distributions of Australian sourced income to securityholders that are not resident in EOI jurisdictions will be subject to WHT at the rate of 30%. The New Zealand sourced income is subject to the corporate tax rate in New Zealand of 28% and is not subject to Australian WHT. The proportion of the payment in respect of the six months ended 30 September 2021 which is attributable to a fund payment from a Clean Building MIT is nil AUD cents per stapled security. The effect of these taxes on the interim distribution has been to reduce the rate of WHT to 9.40653%, equivalent to 0.42598 AUD cents per stapled security, through certain deductions such as depreciation. Thus, tax of 0.42598 AUD cents per stapled security will be withheld from the interim distribution accruing to securityholders and will be paid to the Australian Taxation Office for Australian sourced income. South African securityholder South African income tax implications The implications below are of a general nature and should not be relied upon by securityholders as specific South African income tax advice. It does not purport to be a complete analysis of the potential South African income tax consequences applicable to each securityholder in respect of distributions received/accrued from the Fund. Securityholders should obtain independent income tax advice with regard to the South African income tax consequences of acquiring, holding and disposing of stapled securities having regard to each securityholder’s circumstances. The interim distribution is regarded as a distribution from a foreign trust for South African securityholders. The interim distribution should comprise taxable income and is to be taxed as such dependent on the underlying nature of the income and capital gains noted above, in the hands of South African securityholders. The pre-WHT distribution is to be included in a securityholder’s taxable income and subject to normal tax in full. Tax paying securityholders may be entitled to claim a foreign tax credit equivalent to 9.40653%. For distributions where the South African securityholder only becomes entitled to the distribution in a financial year subsequent to the financial year in which the income or capital gain was earned by the Fund, the South African securityholder may not be able to claim a foreign tax credit. Johannesburg Sponsor Investec Bank Limited Date: 27-10-2021 08:29:00 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.