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Declaration of clean out distribution
SAFARI INVESTMENTS RSA LIMITED
(Incorporated in the Republic of South Africa)
(Registration number: 2000/015002/06)
Approved as a REIT by the JSE Limited
Share code: SAR
ISIN Number: ZAE000188280
("Safari" or "the Company")
DECLARATION OF CLEAN OUT DISTRIBUTION
1. INTRODUCTION
1.1. Unless otherwise defined herein, capitalised words and terms used in this announcement
shall bear the same meanings ascribed thereto in the Circular (defined below).
1.2. Shareholders are referred to the circular issued to Shareholders on Friday, 24 October
2025 ("Circular").
2. CLEAN OUT DISTRIBUTION
2.1. Declaration of Clean Out Distribution
2.1.1. Subject to the Scheme becoming unconditional, which is expected to be on or about
Monday, 8 December 2025, the Board has approved and declared a Clean Out
Distribution of 37,59563 cents per Share. The Clean Out Distribution, following the
deduction of the applicable South African dividend tax of 20%, is 30,07650 cents per
Share for those Shareholders who do not qualify for an exemption from dividend
withholding tax or alternatively, for a reduced dividend withholding rate in terms of the
applicable DTA (defined below).
2.1.2. The Clean Out Distribution is the pro rata roll-forward amount calculated with reference
to Safari's half-yearly dividend from its distributable income for the 6-month period
ending 30 June 2025 (as announced on SENS) for the period from 1 July 2025 until the
Scheme Consideration Record Date and is the greater of the amount determined in
accordance with paragraphs 5.1.1 and 5.1.2 of the Circular.
2.1.3. The expected salient dates and times of the Clean Out Distribution are as follows:
Declaration date Monday, 1 December 2025
Finalisation date Monday, 8 December 2025
Last day to trade Monday, 15 December 2025
Record date Friday, 19 December 2025
Date of payment Monday, 22 December 2025
2.1.4. The number of Shares in issue at the date of declaration, excluding Treasury Shares,
is 255 670 865. The income tax number of the Company is 9012/264/14/0.
2.2. Tax implications
In accordance with the Company's status as a real estate investment trust ("REIT"),
Shareholders are advised that the Clean Out Distribution meets the requirements of a
"qualifying distribution" for the purposes of section 25BB of the Income Tax Act, 58 of 1962
("Income Tax Act"). The Clean Out Distribution will be deemed to be a dividend, for South
African tax purposes, in terms of section 25BB of the Income Tax Act.
2.2.1. Tax implications for South African resident Shareholders
2.2.1.1. The Clean Out Distribution received by or accrued to South African tax residents
must be included in the gross income of such Shareholders and will not be exempt
from income tax (in terms of the exclusion to the general dividend exemption,
contained in paragraph (aa) of Section 10(1)(k)(i) of the Income Tax Act) because it
is a "qualifying distribution" for the purposes of section 25BB of the Income Tax Act.
2.2.1.2. This Clean Out Distribution is, however, exempt from dividend withholding tax in the
hands of South African tax resident Shareholders, provided that such Shareholders
provide the following forms to their CSDP or Broker, as the case may be, in respect
of uncertificated Shares, or the Company, in respect of certificated Shares:
2.2.1.2.1. A declaration that the Clean Out Distribution is exempt from dividend tax; and
2.2.1.2.2. A written undertaking to inform the CSDP, Broker or the Company, as the case
may be, should the circumstances affecting the exemption change or the
beneficial owner cease to be the beneficial owner, both in the form prescribed by
the Commissioner for SARS.
2.2.1.3. Shareholders are advised to contact their CSDP, Broker or the Company, as the
case may be, to arrange for the previously mentioned documents to be submitted
prior to payment of the Clean Out Distribution, if such documents have not already
been submitted.
2.2.2. Tax implications for non-resident Shareholders
2.2.2.1. Distributions received by non-resident Shareholders from a REIT will not be taxable
as income and instead will be treated as ordinary dividends, which are exempt from
income tax in terms of the general dividend exemption in Section 10(1)(k)(i) of the
Income Tax Act. With effect from 1 January 2014, any dividend received by a non-
resident from a REIT will be subject to dividend tax at 20%, unless the rate is reduced
in terms of any applicable agreement for the avoidance of double taxation ("DTA")
between South Africa and the country of residence of the non-resident Shareholder.
2.2.2.2. Assuming dividend tax will be withheld at a rate of 20%, the net Clean Out
Distribution amount due to non-resident Shareholders is 30,07650 cents per share.
A reduced dividend withholding rate in terms of the applicable DTA may only be
relied on if the non-resident Shareholder has provided the following forms to their
CSDP or Broker, as the case may be, in respect of uncertificated shares, or the
Company, in respect of certificated shares:
2.2.2.2.1. A declaration that the Clean Out Distribution is subject to a reduced rate as a
result of the application of a DTA; and
2.2.2.2.2. A written undertaking to inform the CSDP, Broker or the Company, as the case
may be, should the circumstances affecting the reduced rate change or the
beneficial owner cease to be the beneficial owner, both in the form prescribed by
the Commissioner for SARS. If applicable, non-resident Shareholders are
advised to contact their CSDP, Broker or the Company, as the case may be, to
arrange for the previously mentioned documents to be submitted prior to payment
of the Clean Out Distribution if such documents have not already been submitted.
2.2.3. Local tax resident as well as non-resident Shareholders are encouraged to consult their
professional advisors should they be in any doubt as to the appropriate action to take.
3. RESPONSIBILITY STATEMENTS
The Independent Board and the Board, collectively and individually, accept full responsibility
for the accuracy of the information contained in this announcement and certify that, to the best
of their knowledge and belief, such information is true and the announcement does not omit
any facts that would make any of the information false or misleading or would be likely to affect
the importance of any information contained in this announcement.
Pretoria
1 December 2025
Corporate Advisor and Sponsor
Valeo Capital (Pty) Ltd
Legal Advisor
Webber Wentzel
Date: 01-12-2025 11:00:00
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