Dividend Withholding Tax (DWT) - revenue ie

Non-Resident Form V2B 1 Dividend Withholding Tax (DWT) (as provided for by Chapter 8A, Part 6 of the Taxes Consolidation Act, 1997 - “the Act”) EXEMPTION FROM DWT FOR A Qualifying Non-Resident Company DWT UNIT, November 2018 IN RESPECT OF RELEVANT DISTRIBUTIONS Please refer to Notes on Pages 2 & 3 for guidance on completing this form


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RPC011217_EN_WB_L_1Qualifying Intermediary/Authorised Withholding Agent so that exemption can be put in place. Please note the form should not be sent to the DWT Unit for the purpose of gaining ‘exemption-at-source’.Dividend Withholding Tax (DWT)(as provided for by Chapter 8A, Part 6 of the Taxes Consolidation Act, 1997 - “the Act”)EXEMPTION FROM DWT FORA Qualifying Non-Resident CompanyDWT UNIT, November 2018IN RESPECT OF RELEVANT DISTRIBUTIONS
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A “qualifying non-resident person” may receive relevant distributions from companies resident in Ireland without the deduction of DWT where the qualifying non-resident person is bene�cially entitled to the relevant A “qualifying non-resident person” a company which is resident in a “relevant territory”, and which is not under the control (see 5whether directly or indirectly, of a person or persons who is/are resident for the purposes of tax in a company which is ultimately controlled, whether directly or indirectly, by a person or persons who is/a company, the principal class of shares of which, orof a company which is a 75 per cent subsidiary, orwhere the company is wholly owned by 2 or more companies, of each of those companies, ) on a recognised stock exchange in a “relevant Chapter 8A of part 6 of the Taxes Consolidation Act, 1997A company resident in Ireland which makes a relevant distribution directly to the person bene�cially qualifying intermediary, where the relevant distribution has been made indirectly to the person in addition, where relevant distributions are made via an that agent effectively The Revenue Commissioners maintain a list of qualifying intermediaries and authorised withholding agents. https://www.revenue.ie/en/companies-and-charities/dividend-withholding-tax/index.aspxAn exemption from DWT can only be obtained where a completed declaration has been given to the “relevant If the declarant is dealing directly with the Irish paying company, please forward this completed declaration to that paying company.If the declarant is making this declaration via a qualifying intermediary or an authorised withholding agent, please A a country (other than Ireland) which is a member of the European Union, ora country with which Ireland has a Double Taxation Agreement.For up-to-date information on the countries with which Ireland has a Double Taxation Agreement, please consult https://www.revenue.ie/en/tax-professionals/tax-agreements/index.aspx “Control’, is de�ned in Section 172D(3A) to (6) of the Taxes Consolidation Act, 1997, as amended. The key the greater part of the share capital or issued share capital of the Company; orthe greater part of the voting power in the Company; orthe greater part of the distributable income of the Company; orRPC011217_EN_WB_L_1
RPC011217_EN_WB_L_1capital, voting power, distributable income or assets on a winding up are currently possessed, or may in future be ² The term “resident” in the Republic of Ireland” Based on Section 23A of the Taxes Consolidation Act of 1997, as The company is not incorporated in Ireland and does not have its central management and control in The company is incorporated in Ireland, but does not have its central management and control in Ireland, The company or a related company carries on a trade in Ireland, and either the company is ultimately controlled by persons resident in EU Member States or, in countries with which Ireland has a double taxation treaty, or the company or a related company is a quoted company on a recognized Stock The company is regarded as not resident in Ireland under a double taxation treaty between Ireland and another country.³ The term “substantially and regularly traded” is not de�ned in the Taxes Consolidation Act, 1997, as amended. However, for the purposes of qualifying for exemption from DWT under Section 172D, Revenue will accept that a company’s shares are “substantially and regularly traded” where the shares are traded on a regular basis each year in IMPORTANT NOTES:who holds power of attorney from the non-resident company. Where appropriate, a copy of the power of 3. This blank form may be photocopied for use in relation to subsequent declarations. However, in all cases, Co. Tipperary, E45 T611(Tel: +353 676 3105 / Fax: + 353 673 3822 / E-mail: [email protected])
TO BE COMPLETED BY THE DECLARANTCompany Tax Reference number in country of residenceIn the case of a company within the meaning of Section 172D(3)(b)(i) the name of the “relevant territory” _____________________________________________________________________________________In the case of a company within the meaning of Section 172D(3)(b)(ii) the names of the relevant territory or __________________________________________________________________________________________________________________________________________________________________________In the case of a company within the meaning of Section 172D(3)(b)(iii) the name and address of the relevant Name and Address of companyName and Address of stock exchangeperson” for the purposes of Chapter 8A of Part 6 of the Act on the basis that;it satis�es condition [1 or 2 or 3 (delete as appropriate)] as set out above; andit has provided the relevant information requested under the provisions of Section172D(3) as appropriate on Title: (Mr./Ms. etc.):_________ Is this declaration signed under a Power of Attorney:
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