| Wed 14 May 2008, 13:36 | | IPL/ IPLP - Imperial - South African taxation cons |
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IPL IPLP
IPL
IPL/ IPLP - Imperial - South African taxation considerations regarding the
unbundling of shares in Eqstra Holdings Limited ("EQSTRA")
Imperial Holdings Limited
(Incorporated in the Republic of South Africa)
Registration number (1946/021048/06)
Ordinary share code: IPL & ISIN: ZAE000067211
Preference share code: IPLP & ISIN: ZAE000088076
("Imperial" or "the Group")
SOUTH AFRICAN TAXATION CONSIDERATIONS REGARDING THE UNBUNDLING OF SHARES IN
EQSTRA HOLDINGS LIMITED ("EQSTRA")
INTRODUCTION
In the circular issued to Imperial shareholders on 20 March 2008, Imperial
informed its shareholders of the proposed unbundling and distribution of the
ordinary shares held by Imperial in Eqstra ("Eqstra distribution shares") to
Imperial ordinary shareholders recorded in the share register at the close of
business on Friday, 16 May 2008 ("record date"). The unbundling is to be
effected by way of a distribution in specie on Monday, 19 May 2008 in terms of
section 46 of the Income Tax Act, 1962 (Act 58 of 1962)("the Act"), as amended,
in the ratio of one Eqstra distribution share for every Imperial ordinary share
held on the record date.
The purpose of this announcement is to advise Imperial ordinary shareholders of
the closing prices of the Eqstra distribution shares and the Imperial ordinary
shares on Tuesday, 13 May 2008, the day after the distribution of the Eqstra
distribution shares, and the ratio in which the expenditure incurred and/or the
valuation date value of the Imperial ordinary shares must be allocated to the
Eqstra distribution shares and the Imperial ordinary shares ("the apportionment
ratio") for taxation purposes.
Shareholders are advised in all circumstances to seek their own advice regarding
taxation.
APPORTIONMENT RATIO
The apportionment ratio for purposes of section 46 of the Act is 77.8% relating
to an Imperial ordinary share and 22.2% relating to an Eqstra distribution share
based on the closing share prices of Imperial and Eqstra as at 17:00 on 13 May
2008 of R57.87 and R16.50, respectively.
Johannesburg
14 May 2008
Merchant bank, corporate adviser and transaction sponsor
RAND MERCHANT BANK (division of FirstRand Bank Limited)
Sponsor
Merrill Lynch South Africa (Proprietary) Limited
Legal adviser
Tugendhaft Wapnick Banchetti & Partners
Reporting accountants and auditors
Deloitte & Touche
Independent expert
Deloitte & Touche Corporate Finance
Date: 14/05/2008 13:36:00 Produced by the JSE SENS Department.
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