| Tue 20 Dec 2011, 13:05 | | RDF - Redefine Properties Limited - Apportionment ratio for tax purposes |
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RDF - Redefine Properties Limited - Apportionment ratio for tax purposes
Redefine Properties Limited
(Registration No. 1999/018591/06)
JSE code: RDF ISIN Code: ZAE000143178
("Redefine")
APPORTIONMENT RATIO FOR TAX PURPOSES
Redefine linked unitholders are referred to the circular dated 30 September
2011 (the "circular") relating to, inter alia, the unbundling of Arrowhead
shares (the "unbundling")and distribution of Arrowhead debentures to
Redefine linked unitholders in the ratio of 1 Arrowhead A and 1 Arrowhead B
linked unit for every 31.70889 Redefine linked units held.
The purpose of this announcement is to notify Redefine linked unitholders
of Redefine`s calculation of the apportionment ratio (the "apportionment
ratio") between the Arrowhead shares received in terms of the unbundling
(the "unbundled Arrowhead shares") and the Redefine shares in respect of
which the Arrowhead shares were received (the "retained Redefine
shares")for the purposes of section 46 of the Income Tax Act, 1962 (the
"Act").
The apportionment ratio is used to apportion the combined expenditure
(being the original expenditure incurred in respect of the retained
Redefine shares in terms of section 11(a), 22(1) or 22(2) of the Act for
shares held on trading account and paragraph 20 of the Eighth Schedule of
the Act for shares held on capital account) between the unbundled Arrowhead
shares and the retained Redefine shares for the determination of profits
and losses, of a capital or trading nature, on any future disposals of the
unbundled Arrowhead shares or the retained Redefine shares.
The apportionment ratio has been calculated based on the closing prices of
the Redefine and Arrowhead A and B linked units (R7.37, R5.66 and R4.42
respectively) on the 19 December 2011, from which the face values of the
Redefine and Arrowhead A and B debentures (173.58 cents, 101.76 cents and
101.76 cents respectively) has been deducted. Based on this calculation
the apportionment ratio is 2.5% to the unbundled Arrowhead shares forming
part of the Arrowhead A linked units, 1.8% to the unbundled Arrowhead
shares forming part of the Arrowhead B linked units and 95.7% to the
retained Redefine shares.
A summary of the potential South African taxation considerations of the
unbundling for holders of Redefine linked units is set out in Annexure 7 of
the circular. Redefine linked unitholders are, however, advised in all
circumstances to seek their own advice regarding taxation.
Johannesburg
20 December 2011
Corporate advisor, legal advisor and sponsor to Redefine and Arrowhead
Java Capital
Date: 20/12/2011 13:05:00 Produced by the JSE SENS Department.
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