| Fri 6 May 2011, 16:34 | | MVL/NHM - Mvelaphanda Resources Limited/Northam Platinum Limited - SA Tax |
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MVL NHM
MVL NHM
MVL/NHM - Mvelaphanda Resources Limited/Northam Platinum Limited - SA Tax
Considerations regarding the distribution of Northam shares
Mvelaphanda Resources Limited
(Incorporated in the Republic of South Africa)
(Registration number: 1980/001395/06)
Share Code: MVL
ISIN: ZAE000050266
("Mvela Resources")
Northam Platinum Limited
(Incorporated in the Republic of South Africa)
(Registration number: 1977/003282/06)
Share Code: NHM
ISIN: ZAE000030912
("Northam")
SOUTH AFRICAN TAX CONSIDERATIONS REGARDING THE DISTRIBUTION OF 181 980 981
NORTHAM ORDINARY SHARES TO MVELA RESOURCES ORDINARY SHAREHOLDERS ("NORTHAM
DISTRIBUTION")
Allocation of the "tax cost" of the ordinary shares in the capital of Mvela
Resources ("Mvela Resources ordinary shares") on the distribution of the Northam
shares
The purpose of this announcement is to advise Mvela Resources ordinary
shareholders of the closing prices of the Northam shares and the Mvela Resources
ordinary shares on 26 April 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 Northam shares and the Mvela Resources ordinary shares (the "allocation
ratio").
The distribution of the Northam shares by Mvela Resources on Tuesday, 26 April
2011 was an unbundling transaction as contemplated in section 46 of the Income
Tax Act, No. 58 of 1962, as amended. Accordingly all Mvela Resources ordinary
shareholders must determine the portion of the expenditure incurred in respect
of the Mvela Resources ordinary shares that must be attributed to the Northam
distribution shares as follows:
A = B x (C/(C +D))
where:
"A` is the expenditure determined which must be allocated to the Northam
distribution shares;
"B" is the expenditure incurred in relation to the Mvela Resources ordinary
shares;
"C" is the market value of the Northam distribution shares determined at the
close of business after the Northam distribution; and
"D" is the market value of Mvela Resources ordinary shares, determined at the
close of business after the Northam distribution.
Mvela Resources shareholders are advised that the allocation ratio, based on the
relative market values of the Northam shares and the Mvela Resources ordinary
shares at the close of business on 26 April 2011, was as follows:
Closing price Market value Ratio
26/04/2011
R R %
Northam shares 42.00 7,643,201,202 89.70%
distributed
Mvela Resources 4.03 878,060,837 10.30%
ordinary shares
Total 100%
Johannesburg
Date: 6 May 2011
Financial adviser and sponsor to Mvela Resources
J.P. Morgan
Attorneys and tax advisers to Mvela Resources
Bowman Gilfillan
Date: 06/05/2011 16:34:01 Produced by the JSE SENS Department.
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