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Fri 14 Sep 2007, 14:37 SBK - Standard Bank Group Limited - Tax Implicatio
SBK
 SBK                                                                             
SBK - Standard Bank Group Limited - Tax Implications - Interim distribution on  
ordinary shares                                                                 
Standard Bank Group Limited                                                     
(Incorporated in the Republic of South Africa)                                  
(Registration number 1969/017128/06)                                            
South African Share Code: SBK                                                   
Namibian Share Code: SNB                                                        
ISIN: ZAE000057378                                                              
Tax implications - Interim Distribution on Ordinary Shares                      
Background                                                                      
The 2007 interim distribution in respect of Standard Bank Group Limited`s       
ordinary shares, payable on 17 September 2007, amounts to 181 cents per share.  
This distribution partially comprises a return of share premium, and partially  
comprises a distribution of reserves. There are different tax implications      
relating to these two aspects.                                                  
This note discusses these tax implications.                                     
Queries can be referred to: Kim Howard, Director, Investor Relations, +27 11 636
7811                                                                            
South African tax implications                                                  
The 2007 interim distribution in respect of Standard Bank Group Limited`s       
ordinary shares, payable on 17 September 2007, amounts to 181 cents per share.  
This amount has the following components:                                       
(a) Distribution from pure share premium                         24c            
(b) Distribution from share premium sourced from past reserves   76c            
(c) Distribution from distributable reserves                     81c            
The effects of South African tax law are as follows:                            
(a)  Distribution from pure share premium: This portion is treated as a return  
of capital. It is not treated as a dividend. In consequence, it is not      
    subject to Secondary Tax on Companies ("STC") on distribution, and does not 
    qualify as an STC credit in the hands of the recipient, where that          
    recipient is subject to STC. It is a taxable receipt for the purposes of    
Income Tax or Capital Gains Tax ("CGT") - it depends on the recipient`s tax 
    status as to which of these two forms of tax applies. Under the roll-over   
    provisions of the Income Tax Act (8th Schedule, para 76(b)), this taxable   
    receipt only needs to be taken into account for tax purposes when the       
underlying shares are disposed of.                                          
(b)  Distribution from share premium sourced from past reserves: This portion is
    not treated as a return of capital. It is treated as a dividend. In         
    consequence, it is subject to STC on distribution, and does qualify as an   
STC credit in the hands of the recipient, where that recipient is subject   
    to STC.                                                                     
(c)  Distribution from distributable reserves: The position is identical to (b).
    Tax implications in other countries                                         
We cannot advise on the effects of tax law in other countries, and strongly 
    recommend that professional advice be obtained in those countries.          
Sponsor                                                                         
Standard Bank                                                                   
Date: 14/09/2007 14:37:01 Produced by the JSE SENS Department.                  
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