| Mon 24 Nov 2008, 17:37 | | REI - Reinet Investments S.C.A. Depositary Recepits - Information on the |
|
REI
REI
REI - Reinet Investments S.C.A. Depositary Recepits - Information on the
taxation of South African holders of Reinet depositary receipts on the Reduction
of Capital of Reinet Investments S.C.A.
Reinet Investments S.C.A. Depositary Recepits
issued by Richemont Securities AG
(Incorporated in Switzerland)
ISIN: CH0045793657
Depositary Receipt Code: REI
Information on the taxation of South African holders of Reinet depositary
receipts on the Reduction of Capital of Reinet Investments S.C.A.
Background
On 20 October 2008 Compagnie Financiere Richemont S.A. ("CFR") and Reinet
Investments S.C.A. ("Reinet") implemented the de-twinning of Richemont `A` units
into ordinary shares in CFR ("CFR Shares") and participation certificates in
Richemont S.A. ("PCs"); the conversion of Richemont S.A. into Reinet and the
simultaneous conversion of the PCs into ordinary shares in Reinet ("Reinet
Shares"). The CFR Shares were listed on SIX Swiss Exchange and traded on SWX
Europe Limited and the Reinet Shares were listed on the Luxembourg Stock
Exchange on 21 October 2008. Pursuant to the restructuring, former Richemont `A`
unit holders received one CFR Share and one Reinet Share for every Richemont `A`
unit held.
Up to 20 October 2008, Richemont `A` units were traded on the exchange operated
by the JSE Limited ("JSE") in the form of depositary receipts ("Richemont DRs").
To reflect the change in the underlying security, the Richemont DR was split
into depositary receipts in respect of CFR Shares ("CFR DRs") and depositary
receipts in respect of Reinet Shares ("Reinet DRs"). Each Richemont DR holder
therefore received, pursuant to the restructuring, one CFR DR and one Reinet DR
for every Richemont DR held on the record date of the restructuring. CFR DRs and
Reinet DRs are listed on the JSE and trade in the ratio of 10 depositary
receipts for each underlying share.
On 3 November 2008, Reinet distributed 90 per cent of its interest in British
American Tobacco plc ("BAT") to its shareholders and depositary receipt holders.
The distribution was effected against the cancellation of approximately 86.3 per
cent of shareholders` and Reinet DR holders` interests in Reinet. Reinet
shareholders received 0.7083 BAT shares ("BAT Shares") for every Reinet Share
cancelled. Reinet DR Holders received 0.07083 BAT Shares for every Reinet DR
cancelled.
On 14 November 2008, Reinet distributed warrants entitling shareholders to
subscribe for additional Reinet shares. The subscription for the new shares is
to be made in the form of BAT shares. Up to 5 December 2008 the warrants will
trade on the Luxembourg Stock Exchange and warrant receipts will trade on the
exchange operated by the JSE Limited.
Allocation of Richemont DR Capital Gains Tax (CGT) base cost
South African holders of Reinet DRs are referred to paragraph 11 on page 24 of
the supplementary information memorandum published by Richemont Securities AG
("SIM") on 15 August 2008 which explained that South African taxpayers should
allocate the CGT base cost of their Richemont DRs between their CFR DRs and
Reinet DRs. The basis for this allocation was illustrated in the announcement
released on SENS on 30 October 2008 which expressed an apportionment ratio in
respect of the CFR DRs and Reinet DRs based on the market values of the
securities on the first day of their trading. The apportionment ratio set out in
the announcement indicated that the CGT base cost of the Richemont DR should be
allocated 45.7% as to the Reinet DR and 54.3% as to the CFR DR.
Fiscal information in respect of the capital repayment and reduction of profits
Holders of Reinet DRs are advised that 6.8 per cent of the distribution of BAT
Shares effected on 3 November 2008 comprised share capital or share premium of
Reinet; accordingly, 93.2 per cent of the distribution of BAT Shares comprised a
reduction of profits of Reinet. These percentages have been rounded to one
decimal place.
For South African tax purposes, the closing share price of BAT Shares on the JSE
on 31 October 2008 was R266.21 per BAT Share. Therefore, of the R266.21 per BAT
Share distribution, an amount of R18.10 may be treated as a distribution from
share capital or share premium of Reinet and an amount of R248.11 may be treated
as a distribution resulting in a reduction of profits of Reinet.
Holders of CFR and Reinet DRs are advised to seek professional tax and financial
advice. Neither CFR nor Reinet nor Richemont Securities can accept any liability
in respect of the information provided herein nor for the consequences of the
reconstruction steps as they relate to individual unitholders, shareholders or
DR holders.
Further information:
Mr Alan Grieve
Chief Financial Officer
Reinet Investments SCA
Tel: +352 22 7252
24 NOVEMBER 2008
Sponsor
RAND MERCHANT BANK (a division of FirstRand Bank Limited)
Date: 24/11/2008 17:37:01 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.
