Irish Dividend Withholding Tax

Options to Obtain Irish DWT Exemption

Transfer Your Shares to a Broker

Description

• Transfer your shares from Broadridge 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 Broadridge Corporate Issuer Solutions, P.O. Box 1342, Brentwood, NY 11717, 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.

Required Forms

• US Tax Residents need a valid W-9 
• Beneficial ownership form

Continue to hold your Shares in Direct Registry at Broadridge

In order to maintain your Irish DWT exemption beyond the grace period which expired January 1, 2018, you will need to register with and pay a $159.99 (USD) fee to GlobeTax for their eCerts service, which will maintain your exemption through the end of the fifth year following the completion of the required documentation.

$85.00 of the $159.99 service fee is paid to the IRS to obtain the US Certificate of Residency.  $64.99 is retained by GlobeTax for administration of the eCerts service.

You should have initiated your GlobeTax eCerts registration in 2017 to ensure your DWT exemption application was underway before the grace period expired on January 1, 2018.

If you do not act, the statutory dividend withholding tax rate of 25% will be applied to your dividend payments

GlobeTax Registration:

• Click on “Register”
• Use the access code “EATON”
• Follow the instructions provided

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 25% on dividends.

Options to Obtain Irish DWT Exemption

Transfer Your Shares to a Broker

Description

• Transfer your shares from Broadridge 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 Broadridge Corporate Issuer Solutions, PO Box 1342, Brentwood, NY 11717, 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.

Required Forms

• US Tax Residents need a valid W-9 
• Beneficial ownership form

Continue to hold your Shares in Direct Registry at Broadridge

• In order to obtain an Irish DWT exemption, you will need to register with and pay a $159.99 (USD) fee to GlobeTax for their eCerts service, which will maintain your exemption through the end of the fifth year following the completion of the required documentation.
• $85.00 of the $159.99 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 25% will continue to be applied to your dividend payments.

GlobeTax Registration:

• Click on “Register”
• Use the access code “EATON”
• Follow the instructions provided

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 25% on dividends.

Options to Obtain Irish DWT Exemption

Transfer Your Shares to a Broker

Description

• Transfer your shares from Broadridge 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 Broadridge Corporate Issuer Solutions, PO Box 1342, Brentwood, NY 11717, 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 GlobeTax and they can claim the DWT exemption.

Required Forms

• OUS Tax Residents need a valid W8-BEN
• Select the appropriate Form V2 here 
• Beneficial ownership form

Continue to hold your Shares in Direct Registry at Broadridge

• In order to maintain your Irish DWT exemption beyond the grace period which expired January 1, 2018, you needed 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 have initiated your GlobeTax registration in 2017 to ensure your DWT exemption application was underway before the grace period expired on January 1, 2018.
• If you did not act, the statutory dividend withholding tax rate of 25% will be applied to your dividend payments.

GlobeTax Registration:

• Click on “Register”
• Use the access code “EATON”
• Follow the instructions provided

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 25% on dividends.

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.

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 Broadridge:

• If you are a US resident: Form W-9 
• If you are not a US resident: Form W-8BEN

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 Broadridge:

• If you are a US resident: Form W-9 
• If you are not a US resident: Form W-8BEN

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 Broadridge:
• If you are a US resident: Form W-9 
• If you are not a US resident: Form W-8BEN