Dividend Currency Conversion Announcement

Hammerson PLC

14 August 2024

 

Hammerson plc (the "Company")

Dividend Currency Conversion Announcement

14 August 2024

On 25 July 2024, the Company announced that the Board of Directors had declared an interim dividend of 0.756 pence per ordinary share ("Share") for the period ending 31 December 2024 (the "Interim 2024 Dividend").

The Interim 2024 Dividend will be treated as a Property Income Distribution ("PID") and will be subject to a 20% UK withholding tax unless exemptions apply.

The Company will not be offering a scrip dividend alternative but, for shareholders who wish to receive their dividend in the form of Shares, the Dividend Reinvestment Plan ("DRIP") will be available. The terms and conditions of the DRIP can be found at www.signalshares.com. Shareholders registered on the South African Branch Register should contact their CSDP or Broker for further information.

The Interim 2024 Dividend is payable on Monday, 30 September 2024 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 Record Date for both UK Shareholders and SA Shareholders is at the close of business on Friday, 23 August 2024. The DRIP purchases settlement date (subject to market conditions and the purchase of shares in the open market) is Wednesday, 2 October 2024 in the UK and Monday, 14 October 2024 in South Africa. 

The Interim 2024 Dividend should be regarded as a "foreign dividend" for SA income and SA dividend tax purposes and the funds will be paid from the United Kingdom.

Shareholders receiving the Interim 2024 Dividend in cash

The Company confirms that the South African Rand exchange rate for the Interim 2024 Dividend will be ZAR 23.2740 to GBP 1. The Interim 2024 Dividend is payable in South African Rand to SA Shareholders. Shareholders who do not elect the DRIP will be paid as follows:

PID	UK Shareholders (GBP pence)	SA Shareholders (ZAR cents)
Gross amount of PID	0.756	17.59514
Less 20% UK withholding tax/20% SA dividends tax	0.151	3.51903
Net PID dividend payable*	0.605	14.07612
Less 5% SA Shareholders excess reclaim	n/a	0.87976
Net PID dividend payable**	n/a	13.19636

*Net position after SA Shareholders have claimed back 5% from HMRC under the double tax agreement between the United Kingdom and South Africa.

** Before SA shareholders have claimed back 5% from 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 HM Revenue & Customs ("HMRC") in sterling for the total UK withholding tax deducted.

SA dividends tax, at the rate of 20%, will apply to cash PIDs 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 South Africa, 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 South Africa (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 the DRIP

Partial elections are not permitted under the DRIP.

SA Shareholders electing 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 out to these SA Shareholders 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.

Proposed Share Consolidation

The Company published a Circular and Notice of Meeting on 8 August 2024 inviting shareholders to approve resolutions to, among other things, authorise the proposed consolidation, sub-division and re-designation of the Company's ordinary shares. The Proposed Share Consolidation will not impact the Interim 2024 Dividend.

Registered Office	UK Registrars	SA Transfer Secretaries
Marble Arch House 66 Seymour Street London W1H 5BX United Kingdom	Link Group Central Square 29 Wellington Street Leeds LS1 4DL	Computershare Investor Services Proprietary Limited (Registration number 2004/003647/07) 1st Floor, Rosebank Towers 15 Biermann Avenue, Rosebank, 2196 South Africa (Private Bag, X9000, Saxonwold 2132 South Africa)

For further information contact:

Josh Warren

Director of Strategy, Commercial Finance and Investor Relations

Tel: [phone]

[e-mail]

Richard Crowle

Senior Assistant Company Secretary

Tel: [phone]

[e-mail]

The announcement above has also been released on the SENS system of the Johannesburg Stock Exchange and on Euronext Dublin.

This announcement is for information purposes only and is not intended to, and does not constitute or form part of any offer to sell or issue, or the solicitation of an offer to purchase, subscribe for or otherwise acquire any securities of the Company, whether pursuant to this announcement or otherwise.

 

END