Irish Dividend Withholding Tax

Opportunities to Obtain Irish Dividend Withholding Tax (DWT) Exemption

Eaton Corporation plc established tax residence in Ireland during 2012, and as such, dividends are considered Irish source income and Irish dividend withholding tax (“DWT") rules apply. Dividend payments will be subject to an Irish withholding tax of 20% of the amount of each dividend unless the shareholder that is beneficially entitled to the dividend is a resident of the United States or a resident of a country listed as a “relevant territory”, and has ensured that the required documentation is on file with their broker, bank, qualifying intermediary or transfer agent. With these rules, the vast majority of Eaton shareholders and beneficial owners are entitled to an exemption from DWT.

Please answer the following questions to find out how to obtain an exemption from the Irish Dividend Withholding Tax (DWT) on your Eaton Corporation plc shares.  A W-9 or a W8-BEN is still required to avoid United States Dividend Tax withholding.  You may already have these documents on file with your financial institution.

If Irish Dividend Withholding Tax (DWT) has been previously assessed to your account and you are looking for direction on claiming a tax refund or tax credit information click here.

It is up to each individual to review each alternative as it applies to their specific situation, evaluate its viability in the context of your overall investment strategy, and decide which one is right for you.  As part of this process, you may wish to consult your own broker, financial advisor or tax advisor for their professional assistance.  Not all alternatives may be right for you.  Not all alternatives may apply to you.

Q1: Are your Eaton Corporation plc shares held directly with our transfer agent Computershare?
Yes  / No 

Q2: Are your Eaton Corporation plc shares held by a broker and you are a tax resident of the United States?
Yes  / No 

Q3: Was your Computershare account established on or before November 30, 2012?
Yes  / No 

Q4: Are you a resident of a relevant territory (as defined by Irish Law)?  To determine which countries are considered a relevant territory, please visit this link
Yes  / No 

Q5: If you are a resident of a relevant territory, are your shares held with Computershare?
Yes  / No  



Shares Held at Computershare > Filer is Tax Resident of the United States (US) and Account Established before 11/30/12


Options to Obtain Irish DWT Exemption

Description

Required Forms

  • Transfer Your Shares to a Broker
  • Transfer your shares from Computershare to a broker.
  • Ensure that your broker has your Form W-9 on file.
  • Confirm with your broker that they can certify you have a valid US address with a Form W-9.
  • Complete beneficial ownership form regarding the transfer of shares and send to Computershare Tax Department, RE: V2 Processing, PO Box 43001, Providence, RI 02940-3001, within 24 hours of contacting your broker.
  • If your broker has questions on applying for the exemption, they can visit www.dtcc.com and search “Eaton” for instructions.

 

  • Continue to hold your Shares in Direct Registry at Computershare
  • In order to maintain your Irish DWT exemption beyond the grace period which expires January 1, 2018, you will need to register with and pay a $149.99 (USD) service fee to GlobeTax, which will maintain your exemption through the end of the fifth year following the completion of the required documentation.
  • $85.00 of the $149.99 service fee is paid to the IRS to obtain the US Certificate of Residency.  $64.99 is retained by GlobeTax for administration of the service.
  • You should initiate your GlobeTax registration in 2017 to ensure your DWT exemption application is underway before the grace period expires on January 1, 2018.
  • If you do not act, the statutory dividend withholding tax rate of 20% will be applied to your dividend payments.

GlobeTax Registration:

  • Click on “Register”
  • Use the access code “EATON”
  • Follow the instructions provided
  • File Forms with Computershare
  • If you want to continue to hold your shares with Computershare and you have not selected option 1 or 2 to obtain an exemption, the only remaining option is to file a US Certificate of Residency (IRS Form 6166) and the Irish V2 form with Computershare to maintain your DWT exemption.
  • There is no charge from Computershare to file these forms.
  • You must pay an $85 fee to the IRS and file the IRS Form 8802, which is the application required by the IRS to issue the US Certificate of Residency (Form 6166).  The 6166 and V2 need to be lodged with Computershare prior to the dividend record date in March 2018.

 

  • US IRS-8802 to obtain the IRS Form 6166; file 6166 with V2 with Computershare
  • A W-9 will need to be on file with Computershare
  • Sell your shares

Eaton values all shareholders and hopes you remain a shareholder.  However, we understand that, after reviewing each alternative and evaluating its viability in the context of your overall investment strategy, you might decide this alternative is right for you.
If you sell your ETN shares, and don’t purchase new ETN shares, you will not receive dividends – and will not be required to pay Irish DWT.
You should consult your tax advisor regarding the tax consequences of selling your shares.
If you take no action, Irish DWT will be withheld from your Eaton Corporation plc dividend payments.  The dividend payment you receive will be reduced by the Irish DWT
Irish DWT is withheld at a rate of 20% on dividends.

 


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Tax Resident of US with Shares Held by Broker (US)
You should be exempt from paying the Irish DWT, assuming:

  • You have a Form W-9 and a valid United States address on file with your broker; and
  • You’ve confirmed with your broker that they can certify a valid US address with a Form W-9.

If your broker has questions on applying for the Irish DWT exemption, they can visit http://www.dtcc.com and search “Eaton” for instructions.  These instructions also include details on the treatment of special situations, such as trusts or partnerships.  Generally, for US Tax Residents, the DTC Participants are automatically considered a Specified Intermediary and can claim the exemption based on the investor’s US address.  For Non-US Tax Residents, their U.S. banks or brokers (aka DTC Participants), who are not Qualifying Intermediaries, send the Form V2 to BNY Mellon as the Qualified Intermediary and they can claim the DWT exemption.


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Shares Held at Computershare > Filer is Tax Resident of the United States (US) and Account Established after 11/30/12


Options to Obtain Irish DWT Exemption

Description

Required Forms

  • Transfer Your Shares to a Broker
  • Transfer your shares from Computershare to a broker.
  • Ensure that your broker has your Form W-9 on file.
  • Confirm with your broker that they can certify you have a valid US address with a Form W-9.
  • Complete beneficial ownership form regarding the transfer of shares and send to Computershare Tax Department, RE: V2 Processing, PO Box 43001, Providence, RI 02940-3001, within 24 hours of contacting your broker.
  • If your broker has questions on applying for the exemption, they can visit www.dtcc.com and search “Eaton” for instructions.

 

  • Continue to hold your Shares in Direct Registry at Computershare
  • In order to obtain an Irish DWT exemption, you will need to register with and pay a $149.99 (USD) service fee to GlobeTax, which will maintain your exemption through the end of the fifth year following the completion of the required documentation.
  • $85.00 of the $149.99 service fee is paid to the IRS to obtain the US Certificate of Residency.  $64.99 is retained by GlobeTax for administration of the service.
  • To ensure your Irish DWT exemption, initiate your GlobeTax registration as soon as possible, at least 45 days prior to the dividend record date.
  • If you do not act, the statutory dividend withholding tax rate of 20% will continue to be applied to your dividend payments.

GlobeTax Registration:

  • Click on “Register”
  • Use the access code “EATON”
  • Follow the instructions provided
  • File Forms with Computershare
  • If you want to continue to hold your shares with Computershare and you have not selected option 1 or 2 to obtain an exemption, the only remaining option is to file a US Certificate of Residency (IRS Form 6166) and the Irish V2 form with Computershare to obtain a DWT exemption.
  • There is no charge from Computershare to file these forms.
  • You must pay an $85 fee to the IRS and file the IRS Form 8802, which is the application required by the IRS to issue the US Certificate of Residency (Form 6166).  The 6166 and V2 need to be lodged with Computershare prior to the dividend record date.

 

  • US IRS-8802 to obtain the IRS Form 6166; file 6166 with V2 with Computershare
  • A W-9 will need to be on file with Computershare
  • Sell your shares

Eaton values all shareholders and hopes you remain a shareholder.  However, we understand that, after reviewing each alternative and evaluating its viability in the context of your overall investment strategy, you might decide this alternative is right for you.
If you sell your ETN shares, and don’t purchase new ETN shares, you will not receive dividends – and will not be required to pay Irish DWT.
You should consult your tax advisor regarding the tax consequences of selling your shares.
If you take no action, Irish DWT will be withheld from your Eaton Corporation plc dividend payments.  The dividend payment you receive will be reduced by the Irish DWT
Irish DWT is withheld at a rate of 20% on dividends.

 

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Shares Held at Computershare > Filer is Tax Resident outside the United States (OUS) in a Relevant Territory (as defined by Irish Law) and Account Established before 11/30/12


Options to Obtain Irish DWT Exemption

Description

Required Forms

  • Transfer Your Shares to a Broker
  • Transfer your shares from Computershare to a broker.  To ensure continuation of the exempt status you may already have in place, we recommend that this transfer occur in 2017.
  • Ensure that your broker has your stamped Form V2 on file.
  • Confirm with your broker that they will file the Irish DWT exemption.
  • Complete beneficial ownership form regarding the transfer of shares and send to Computershare Tax Department, RE: V2 Processing, PO Box 43001, Providence, RI 02940-3001, within 24 hours of contacting your broker.
  • If your broker has questions on applying for the exemption, they can visit www.dtcc.com and search “Eaton” for instructions.  For Non-US Tax Residents, the DTC participants send the Form V2 to Computershare and they can claim the DWT exemption.

 

  • Continue to hold your Shares in Direct Registry at Computershare
  • In order to maintain your Irish DWT exemption beyond the grace period which expires January 1, 2018, you will need to register with and pay a $50 (USD) service fee to GlobeTax, which will maintain your exemption through the end of the fifth year following the completion of the required documentation.
  • You should initiate your GlobeTax registration in 2017 to ensure your DWT exemption application is underway before the grace period expires on January 1, 2018 and before the next dividend record date.
  • If you do not act, the statutory dividend withholding tax rate of 20% will be applied to your dividend payments.

GlobeTax Registration:

  • Click on “Register”
  • Use the access code “EATON”
  • Follow the instructions provided
  • File Forms with Computershare
  • You need to obtain the proper forms and file them with Computershare before the grace period expires on January 1, 2018 to obtain the Irish DWT exemption.
  • There is no charge from Computershare to file these forms.

 

  • Ireland Department of Revenue Forms
  • Sell your shares

Eaton values all shareholders and hopes you remain a shareholder.  However, we understand that, after reviewing each alternative and evaluating its viability in the context of your overall investment strategy, you might decide this alternative is right for you.
If you sell your ETN shares, and don’t purchase new ETN shares, you will not receive dividends – and will not be required to pay Irish DWT.
You should consult your tax advisor regarding the tax consequences of selling your shares.
If you take no action, Irish DWT will be withheld from your Eaton Corporation plc dividend payments.  The dividend payment you receive will be reduced by the Irish DWT
Irish DWT is withheld at a rate of 20% on dividends.

 

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Filer is Tax Resident Outside the United States (OUS) and does not reside in a Relevant Territory (as defined in Irish Law)
It is likely that you are not exempt from paying the Irish DWT.  Check with your tax advisor to see if there are any options that apply to your special situation.


The only remaining option to avoid DWT may be to sell your shares

Eaton values all shareholders and hopes you remain a shareholder.  However, we understand that, after reviewing each alternative and evaluating its viability in the context of your overall investment strategy, you might decide this alternative is right for you.
If you sell your ETN shares, and don’t purchase new ETN shares, you will not receive dividends – and will not be required to pay Irish DWT.
You should consult your tax advisor regarding the tax consequences of selling your shares.

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Filer is resident of a Relevant Territory Outside the US with Shares Held by Broker (OUS)
To receive an Irish DWT exemption:

  • Ensure your broker has your Form V2 on file, which is available here 
  • Confirm with your broker that they will file the Irish DWT exemption

If your broker has questions on applying for the exemption, they can visit http://www.dtcc.com and search “Eaton” for instructions.  These instructions include country-by-country filing requirements as well as instructions of special situations, such as trusts or partnerships.  For Non-US Tax Residents, their U.S. banks or brokers (aka DTC Participants), who are not Qualifying Intermediaries, send the Form V2 to BNY Mellon as the Qualified Intermediary and they can claim the DWT exemption in that manner.


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This page is intended to give helpful direction to holders who have had Irish Dividend Withholding Tax (DWT) applied to their account and are looking for information on claiming a tax refund or tax credits.  Investors should not view this detail as a substitute for a knowledgeable tax advisor and we advise that you seek their guidance in these often complex tax situations.


I am a United States Tax Resident.  How do I claim a refund of Irish DWT from the Irish Tax Authority?
  • If you do not obtain an exemption from Irish DWT, you may apply for a refund directly from the Irish Tax Authority.
  • Refund claims may be made in the same year as the Irish DWT was withheld, however, they must be made within four year from the end of the calendar year in which the tax was deducted  (e.g. a refund claim for Irish DWT withheld in May 2017 must be made by 31 December 2021).
  • Total cost over five years includes a $85 (USD) IRS “user fee,” plus postage/courier fees.
  • Refunds are issued by the Irish Revenue Commissioners in € Euros by check.
  • It is common for refunds filed directly to the Irish Revenue Commissioners to take 9-12 months to pay.
  • GlobeTax may be able to assist you for a fee per share subject to a minimum fee (in addition to the $85 paid to the IRS), but you do not need to use GlobeTax to claim a refund of Irish DWT.
  • If you wish to use GlobeTax, contact them at eCertsEaton@globetax.com.
  • Refunds paid through GlobeTax will be made in $ USD by check.
  • Refunds through GlobeTax are often received in half the time as filing directly.
  • File Form US IRS-8802  with the IRS, paying the $85 (USD) “user fee,” to obtain IRS Form 6166.
  • Submit to Irish Revenue the following forms using tracking mail (e.g. FedEx, UPS, DHL, certified mail via USPS, or similar):
    • Completed refund claim form
    • Original dividend vouchers
    • Form 6166*
    • Form V2*
    • All other forms required by Irish Revenue: refer to the “Dividend Withholding Tax Refund Claim Form – Claim from or on behalf of Certain Non-Resident Persons for Refund of DWT”. 

* You do not need to complete these new forms with each refund claim; these forms are valid for the year in which they are signed, plus five full calendar years following.
You will still need to submit one of these forms to Computershare:

I am tax filer residing outside the United States.  How do I claim a refund of Irish DWT from the Irish Tax Authority?

  • If you do not obtain an exemption from Irish DWT, you may apply for a refund directly from the Irish Tax Authority.
  • Refund claims may be made in the same year as the Irish DWT was withheld, however, they must be made within four years from the end of the calendar year in which the tax was deducted (e.g. a refund claim for Irish DWT withheld in March 2018 must be made by 31 December 2022).
  • Total costs over five years are postage/courier fees.
  • Refunds are issued by the Irish Revenue Commissioners in € Euros by check.
  • GlobeTax may be able to assist you for a fee per share subject to a minimum fee, but you do not need to use GlobeTax to claim a refund of Irish DWT.
  • If you wish to use GlobeTax, contact them at eCertsEaton@globetax.com.
  • Refunds paid through GlobeTax will be made in $ USD by check.
  • Refunds through GlobeTax are often received in half the time as filing directly.

 

  • Submit to Irish Revenue the following forms using tracking mail (e.g. FedEx, UPS, DHL, certified mail via USPS, or similar):
    • Completed refund claim form
    • Original dividend vouchers
    • Form V2*
    • All other forms required by Irish Revenue: refer to the “Dividend Withholding Tax Refund Claim Form – Claim from or on behalf of Certain Non-Resident Persons for Refund of DWT”. 

* You do not need to complete these new forms with each refund claim; these forms are valid for the year in which they are signed, plus five full calendar years following.
You will still need to submit one of these forms to Computershare:

Claim a foreign tax credit on your income tax return for the Irish DWT you paid

  • It can be difficult to satisfy the requirements for a tax credit.  You should consult your tax advisor to see if this is possible.
  • You should consult your individual tax advisor to see what additional forms you may need to file with your income tax return, if any.
  • You will still need to submit one of these forms to Computershare:
  • If you are a US resident: Form W-9 
  • If you are not a US resident: Form W-8BEN 

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Helpful Web Resources

Web Resource

 

Link

US Depository Trust Clearing Company (DTC)

 

http://dtcc.com/

DTC Tax Relief by Country FAQs

 

http://www.dtcc.com/asset-services/global-tax-services/tax-relief-by-country
Click on: DTC TaxReliefsm FAQ: Ireland

US IRS Form W-9

 

https://irs.gov/pub/irs-pdf/fw9.pdf

US IRS Form W8-BEN

 

http://irs.gov/pub/irs-pdf/fw8ben.pdf

US IRS Form 8802

 

https://irs.gov/pub/irs-pdf/f8802.pdf

US IRS International Tax Payers

 

https://www.irs.gov/Individuals/International-Taxpayers

US IRS International Tax Payer Identification Numbers

 

https://www.irs.gov/individuals/international-taxpayers/taxpayer-identification-numbers-tin

 

http://www.revenue.ie/en/practitioner/law/tax-treaties.html

Ireland Verified List of Authorized Qualifying Intermediaries & Withholding Agents

 

http://www.revenue.ie/en/tax/dwt/authorised-qualifying-intermediaries.html

Ireland DWT Forms

 

http://www.revenue.ie/en/tax/dwt/forms/

Ireland Taxes & Duties

 

http://www.revenue.ie/en/tax/index.html

GlobeTax

 

https://ecerts.globetax.com/

GlobeTax Contact Information

 

https://www.globetax.com/ContactUs.aspx

Computershare Trust Company N.A.

 

https://www.computershare.com

Beneficial Ownership Form

 

Beneficial Ownership Form


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