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General SENS Submitter Company - TAX CONSIDERATIONS IN RESPECT OF THE SCHEME CONSIDERATION RECEIVED PURSUANT TO THE TRANSACTION

Release Date: 14/01/2026 13:29
Code(s): GSSC     PDF:  
Wrap Text
TAX CONSIDERATIONS IN RESPECT OF THE SCHEME CONSIDERATION RECEIVED PURSUANT TO THE TRANSACTION

CURRO HOLDINGS LIMITED
Incorporated in the Republic of South Africa
(Registration number: 1998/025801/06)
("Curro" or "the Company")




TAX CONSIDERATIONS IN RESPECT OF THE SCHEME CONSIDERATION RECEIVED
PURSUANT TO THE TRANSACTION


All capitalised terms used but not defined in this announcement shall bear the meanings
ascribed to them in the Circular.

Investors are referred to various announcements the last of which was released on SENS on
Friday, 9 January 2026 in relation to the acquisition by the trustees for the time being of the
Jannie Mouton Stigting of all of the ordinary shares in and the subsequent delisting of the
ordinary shares of Curro from the JSE Limited, on the further terms and conditions set out in
the Circular.


For clarification purposes, the Company hereby advises that on Friday, 9 January 2026, being
the date for determining the market value for calculating the STT payable by Scheme
Participants, the closing price of a Capitec Share and PSG Financial Services Share were as
follows:
                                   Closing Price at close of trade on Friday, 9 January 2026
 Capitec Share                     R4185.89
 PSG Financial Services Share      R26.89


The Company further advises that on Tuesday, 6 January 2026, being the date for determining
the market value for calculating the CGT/income tax payable by Scheme Participants and the
base cost of the new shares acquired, the closing price of a Curro Share was as follows:
                                   Closing Price      at   close   of   trade   on   Tuesday,
                                   6 January 2026
 Curro Share                       R14.61


Scheme Participants are referred to Annexure 4 of the Circular for further tax considerations
arising from the implementation of the Scheme.
The expenditure or base cost incurred to acquire the Consideration Shares (being PSG
Financial Services Shares and the Capitec Shares) is to be determined with reference to the
market value of the Curro Shares at which the exchange takes place (duly apportioned
between the Capitec Shares and PSG Financial Services Shares). The market value is the
ruling price of the Curro Shares at which the exchange takes place being the last day to trade
in respect of a Curro Share, which was Tuesday, 6 January 2026.
As set out in the Circular, if any Cash Consideration is received by a Scheme Participant, it is
a separate asset that also needs to be taken into account in addition to the market value of
the Curro Shares, to determine the collective base cost of the Consideration Shares as
contemplated in paragraph 20(1)(a) of the Eighth Schedule.
Please note that neither this announcement nor the Circular constitutes tax advice, and
Scheme Participants are advised to obtain their own professional advice in this regard in
circumstances where one is dealing with a barter arrangement where counters are effectively
exchanged for each other. In other words, Curro Shares are exchanged for shares in Capitec
and PSG Financial Services.
Bellville
14 January 2026

Transaction Advisor and Sponsor
PSG Capital

Legal Advisor
Cliffe Dekker Hofmeyr Inc.

Independent Sponsor
BSM Sponsors

Date: 14-01-2026 01:29:00
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