27 Oct - 6 min read

Interim distribution

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
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