Important:
This answer is based on tax law year ending 28 February 2017.
Answer:
From our understanding of the requirement in section 64K(1A) of the Income Tax Act, a company (a REIT must be a company) must submit a return to SARS if the company paid the dividend. This is the DRT01 and DTR02 return. The fact that the dividend is exempt from the dividends tax is not relevant where the company paid the dividend. We submit that the DTR returns are therefore required.
We tried to confirm this with SARS, but have been unable to do so. You may want to confirm our understanding with SARS.