Dividend Declaration

RNS Number : 6373O

Hammerson PLC

22 August 2017

 

Hammerson plc

22 August 2017

Dividend Currency Conversion Announcement

Dividend No. 133

On 26 July 2017, the Company declared an interim dividend of 10.70 pence per share ("the Dividend") for the period ended 30 June 2017.  The Dividend will be subject to a 20% UK withholding tax unless exemptions apply and will be treated as a Property Income Distribution ("PID"). 

The Dividend Reinvestment Plan ("DRIP") will be available for those shareholders who wish to receive the Dividend in the form of shares.  The Dividend is payable on Monday, 9 October 2017 to shareholders registered on the UK principal register ("UK Shareholders") and the South African branch register ("SA Shareholders") who have elected to receive the Dividend in cash.  The DRIP purchases settlement date (subject to market conditions and the purchase of shares in the open market) is Monday, 16 October 2017.  The Record Date for both UK Shareholders and SA Shareholders is at the close of business on Friday, 1 September 2017.

The Dividend should be regarded as a "foreign dividend" for South African income and dividends tax purposes.

Shareholders receiving the Dividend in cash

The Company confirms that the South African Rand exchange rate for the Dividend will be ZAR 17.12290 to GBP 1.  The Dividend is payable in South African Rand to SA Shareholders.  Accordingly, shareholders who do not elect for the DRIP will be paid as follows:

PID	UK Shareholders (GBP pence)	SA Shareholders (ZAR cents)
Gross amount of PID	10.70p	183.21503 cents
Less 20% UK withholding tax/20% SA dividends tax*	2.14p	36.64301 cents
Net PID dividend payable	8.56p	146.57202 cents

*Please note that this is the net position after SA Shareholders have claimed back 5% from Her Majesty's Revenue & Customs ("HMRC") under the double tax agreement between the United Kingdom and South Africa.

Cash PIDs

A 20% UK withholding tax will be deducted from cash PIDs. The Company will account to HMRC in sterling for the total UK withholding tax deducted.

SA dividends tax, at the rate of 20% will apply to cash PIDs and dividends payable by the Company unless the beneficial owner of the dividend is exempt from SA dividends tax (e.g. if it is a South African resident company). Under the double tax agreement between the UK and SA ("the DTA"), the maximum tax payable in the UK is 15%.  South African resident shareholders are therefore entitled to claim the excess of 5% from HMRC.  As SA Shareholders are entitled to reclaim this excess from HMRC, the maximum rebate allowable in respect of the UK withholding tax against the SA dividends tax is 15%, which means that the Company will have to withhold a further 5% from the dividend in South Africa to bring the total dividends tax to 20%.  In summary, therefore, 20% will be withheld in the UK, a further 5% will be withheld in SA (where appropriate), but South African resident shareholders will be entitled to claim back 5% from HMRC which will bring the overall total to 20%.

Shareholders electing for the DRIP

SA Shareholders electing for the DRIP should note that, in respect of fractional entitlements that may arise, all allocations of shares will be rounded down to the nearest whole number, and any residual amounts that are not used to reinvest in shares (as a result of rounding down) will be paid in cash.

It is the Company's understanding that the residual cash paid to SA Shareholders who have made DRIP elections would already have been taxed prior to the calculation of the number of shares and any residual cash owing to such SA Shareholders.  Accordingly, no further tax should be payable on the cash paid to SA Shareholders as a result of any fractional entitlements.

The above information and the guidelines on the taxation of dividends are provided as a general guide based on the Company's understanding of the law and practice currently in place.  Any shareholder who is in any doubt as to their tax position should seek independent professional advice.

Registered Office	UK Registrars	SA Transfer Secretaries
Kings Place 90 York Way London N1 9GE United Kingdom	Capita Asset Services The Registry 34 Beckenham Road Beckenham Kent BR3 4TU United Kingdom	Computershare Investor Services Proprietary Limited (Registration number 2004/003647/07) 1st Floor, Rosebank Towers, 15 Biermann Avenue, Rosebank, 2196 South Africa (PO Box 61051, Marshalltown, 2107, South Africa)

Sarah Booth

General Counsel and Company Secretary

The announcement above has been released on the SENS system of the Johannesburg Stock Exchange.

 

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