You have been working as a Tax Consultant at a Tax Consulting Firm for the past several years and are well known for being an expert when it comes to complex dividend and Amas itsion tanactions$,$ You were given the tolowing matter t resole.Matter $1$Magnetic Limited is a resident of the Republic of South Africa. Magnetic Limited's equity shares are held as follows:$*25\%$ by non$-$residents from a country where the agreed tax rate on dividends cannot exceed $5\%.*35\%$ by beneficial owners who are not exempt from the dividends tax$\mathrm{.}28\%$ by beneficial owners who are exempt from the dividends tax. $12\%$ by a regulated intermediary.On $28$ February $2023,$ Magnetic Limited declared a dividend of R$560000$ to the company's shareholders.Matter $2$Sports $($Pty$)$ Limited, a resident of the Republic of South Africa, has two resident shareholders, Mrs$.$ Themba who holds $45\%$ of the shares in Sports $($Pty$)$ Limited, and Mr$.$Thabo, who holds the remaining $55\%$ of the shares. During the company's financial year which ended on $28$ February $2023,$ Sports $($Pty$)$ Limited made the following distributions:$*$ Sports $($Pty$)$ Limited invested some of the excess cash reserves of the company in shares of a JSE$-$listed company, Fitness Limited. On $31$ March $2022,$ these shares in Fitness Limited were distributed to Mrs$.$ Themba and Mr$.$ Thabo. The quoted value of the Fitness Limited shares held by Sports $($Pty$)$ Limited at the close of business was R$980000$ on $30$ March $2022$ and R$1100000$ on $31$ March $2022.*$ A dividend of R$3100000$ was declared on $30$ September $2022.$ Mrs$.$ Themba elected to receive her portion of the dividend in cash, while a building to the value of R$1705000$ was transferred to Mr$.$ Thabo in respect of his portion of the dividend.Matter $3$Techno $($Pty$)$ Limited, a resident of the Republic of South Africa, was voluntarily liquidated on $31$ June $2023$ and distributed R$1800000$ to its holders of equity shares. R$250000$ of the R$1800000$ represented a reduction in Techno $($Pty$)$ Limited's contributed tax capital.

REQUIRED:$2\mathrm{.}1$ With reference to Matter $1,$ calculate the dividends tax to be withheld by Magnetic Limited on the dividend declared on $28$ February $2023.$Show all your calculations and round your answers to the nearest rand.$(8$ marks$)2\mathrm{.}2$ With reference to Matter $2,$ calculate the dividends tax per distribution and clearly state who is liable for the dividends tax.Show all your calculations and round your answers to the nearest rand$\mathrm{.}2\mathrm{.}3$ With reference to Matter $3,$ discuss if the distribution of R$1800000$ is a 'dividend'.Support your answer with references to the relevant sections in the Income Tax Act.