| Wed 2 Feb 2011, 17:29 | | MVL - Mvelaphanda Resources Limited - SA Tax Considerations regarding the |
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MVL
MVL
MVL - Mvelaphanda Resources Limited - SA Tax Considerations regarding the
distribution of Gold Fields shares
Mvelaphanda Resources Limited
(Incorporated in the Republic of South Africa)
(Registration number: 1980/001395/06)
Share Code: MVL
ISIN: ZAE000050266
("Mvela Resources")
SOUTH AFRICAN TAX CONSIDERATIONS REGARDING THE DISTRIBUTION
BY MVELA RESOURCES OF 22 218 000 ORDINARY SHARES IN THE CAPITAL OF GOLD FIELDS
LIMITED ("Gold Fields shares") TO HOLDERS OF ORDINARY SHARES IN ITS CAPITAL
("Mvela Resources ordinary shareholders")
Allocation of the tax cost of the ordinary shares in the capital of Mvela
Resources ("Mvela Resources ordinary shares") on the distribution of the Gold
Fields shares
The purpose of this announcement is to advise Mvela Resources ordinary
shareholders of the closing prices of the Gold Fields shares and the Mvela
Resources ordinary shares on 28 January 2011, and of the ratio in which the
expenditure incurred in connection with the acquisition of the Mvela Resources
ordinary shares, or their valuation date values, as the case may be, must be
allocated to the Gold Fields shares and the Mvela Resources ordinary shares (the
"allocation ratio").
The distribution of the Gold Fields shares by Mvela Resources on 31 January 2011
was a capital distribution under paragraph 76 of the Eighth Schedule of the
Income Tax Act, No. 58 of 1962, as amended (but outside of the section 46
unbundling provisions). This requires each Mvela Resources ordinary shareholder
to treat the distribution as a "part" disposal of their Mvela Resources ordinary
shares in terms of paragraph 76A of the Eighth Schedule. The "proceeds" of the
part disposal is regarded as being the market value of the Gold Fields shares
distributed to the Mvelaphanda Resources ordinary shareholders. To calculate the
"base cost" of the part of the Mvela Resources ordinary shares deemed to have
been disposed of, the Mvela Resources ordinary shareholders must allocate part
of the expenditure incurred in connection with the acquisition of the Mvela
Resources ordinary shares and/or the valuation date value of the Mvela Resources
ordinary shares, as the case may be, to the Gold Fields shares and the Mvela
Resources ordinary shares, pro rata, based on their relative market values at
the close of business on the last business day prior to the distribution.
Mvela Resources shareholders are advised that the allocation ratio, based on the
relative market values of the Gold Fields shares and the Mvela Resources
ordinary shares at the close of business on 28 January 2011, was as follows:
Closing price Market value Ratio
28/01/2011
R R %
Gold Fields 111.82 2 484 416 760 24.91%
shares
distributed
Mvela 37.09 8 081 209 999 75.09%
Resources
ordinary
shares
Total 100%
Johannesburg
Date: 2 February 2011
Financial adviser and sponsor to Mvela Resources
J.P. Morgan
Attorneys and tax advisers to Mvela Resources
Bowman Gilfillan
Independent reporting accountants
PricewaterhouseCoopers Inc.
Date: 02/02/2011 17:29:01 Produced by the JSE SENS Department.
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