Mediclinic International plc
(Incorporated in England and Wales)
Company Number: 08338604
LSE Share Code: MDC
JSE Share Code: MEI
NSX Share Code: MEP
("Mediclinic" or "the Company")
5 December 2016
TAX TREATMENT OF ORDINARY SHARE DIVIDEND FOR SHAREHOLDERS ON THE SOUTH AFRICAN REGISTER
Shareholders on the South African register of the Company are referred to Mediclinic's interim results for the six months ended 30 September 2016 and declaration of dividend announcement released on the Stock Exchange News Service and on the Regulatory News Service on 10 November 2016, confirming that the Board of Directors of Mediclinic had declared an interim dividend from retained earnings of 3.20 pence per ordinary share for the six months ended on 30 September 2016.
Shareholders on the South African register will be paid the ZAR cash equivalent of 3.20 pence per ordinary share, being 53.31200 cents (45.31520 cents net of dividend withholding tax) per ordinary share (based on the 5 day average ZAR/GBP exchange rate on Friday, 4 November 2016, being GBP1/ZAR16.66). A dividend withholding tax of 15% will be applicable to all shareholders on the South African register who are not exempt therefrom.
The interim dividend will be paid on Monday, 12 December 2016 to all Mediclinic shareholders who were recorded on the Company's register of members at the close of business on the record date, being Friday, 25 November 2016.
The Company wishes to clarify the tax treatment of the dividend payable to Mediclinic shareholders on the South African register.
South African tax resident shareholders on the South African register:
In terms of the Company's Dividend Access Trust structure, the following South African tax resident shareholders on the South African register will receive a component of the dividend, namely 31.29280 cents per share, from the Dividend Access Trust and therefore regarded as a local South African dividend, with the remaining component, namely 22.01920 cents per share, from the Company and therefore regarded as a foreign non-South African dividend. For purposes of South African dividend withholding tax, the entire dividend of 53.31200 cents per share is taxable at a rate of 15%, unless an applicable exemption applies:
in the case of shares held in certificated form, who are registered on the South African register with an address in South Africa (other than PLC Nominees Proprietary Limited (or any successor entity through which shares held in dematerialised form are held)); and
in the case of shares held in dematerialised form, in respect of whom the South African transfer secretaries of the Company have determined, in good faith and by reference to the information provided to them by the eligible shareholders and/or their brokers and/or central securities depository participants, that such eligible shareholders are either (i) tax resident in South Africa or (ii) have an address in South Africa and have not expressly indicated that they are not tax resident in South Africa as at the dividend record date.
Non-South African tax resident shareholders on the South African register:
Non-South African tax resident shareholders on the South African register will be paid the dividend by the Company in the usual way and not through the Dividend Access Trust. The entire dividend of 53.31200 cents per share payable to such shareholders will therefore be regarded as a foreign dividend and exempt from South African dividend withholding tax, provided that the relevant exemption forms have been completed and submitted as prescribed.
Registered address: 1st Floor, 40 Dukes Place, London, EC3A 7NH, United Kingdom
Corporate broker: Morgan Stanley & Co International plc
JSE sponsor: RAND MERCHANT BANK (A division of FirstRand Bank Limited)
NSX sponsor: Simonis Storm Securities (Pty) Ltd