Ireland: change of issuer CSD - impact on reclaims of withholding tax on dividends

11.06.2021

Clearstream Banking1  would like to inform customers that the tax voucher and nominee statement from the issuer CSD will no longer be required in order to submit reclaim of withholding tax on dividends distributed by Irish taxable equities held with the Irish domestic depository and paid after 15 March 2021.

Background

Prior to the change of issuer CSD for Irish corporate securities (from Euroclear UK and Ireland to Euroclear Bank as described in our Announcement A21046), customers of Clearstream Banking could introduce a standard reclaim of withholding tax on dividends from Irish taxable equities to Clearstream Banking, provided that some tax certification requirements were met. While the tax certifications requirement varied depending on the eligibility of the final beneficial owner, a tax voucher and nominee statement from the issuer CSD was mandatory in each case.

On 15 March 2021, Euroclear Bank became the issuer CSD for Irish corporate securities, resulting in a change in the tax processes to reclaim withholding tax on dividends paid from Irish taxable equities.

Impact on customers

The following changes apply to Clearstream Banking customers wishing to introduce a standard reclaim of withholding tax on Irish dividends paid after 15 March 2021:

  • tax vouchers and nominee statements are no longer a requirement to submit a standard reclaim of withholding tax;
  • the full chain of credit advices from the issuer CSD’s participant to the final beneficial owner has to be provided to Clearstream Banking for each standard reclaim submission. Each credit advice of the chain should mention (i) an express reference of the Euroclear Bank participant account number (on which the Irish income was paid to) and (ii) an instruction to the next intermediary to quote the same Euroclear Bank participant account number on the credit advices the next intermediary may issue.

As a result, prior to any standard reclaim submission, customers of Clearstream Banking are invited to request Clearstream Banking’s credit advice by email to creation.creditadvice@clearstream.com. The email should mandatorily mention the following information:

  • Account number;
  • ISIN code
  • Income Pay date;
  • Tax Rate for which the credit advice is requested;
  • Postal address to which the original credit advice should be delivered.

Clearstream Banking will in turn provide the customer with the credit advices from Clearstream Banking (in original and copy via email), both quoting the Euroclear Bank participant account, within an average timeframe of one month.

Upon reception of the full standard reclaim file, Clearstream Banking will attach Euroclear Bank participant’s credit advice to the file prior submission to the Irish tax authorities.

Please note that such change in the processes has also been reflected on Form “Claim for refund of Dividend Withholding Tax (DWT)" available on Irish tax authorities website.

The other tax certification requirements remain unchanged, as described in our Tax Guide.

Further information

For further information, please contact the Clearstream Banking Tax Help Desk, Clearstream Banking Client Services or your Relationship Officer.

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1. Clearstream Banking refers collectively to Clearstream Banking S.A., registered office at 42, avenue John F. Kennedy, L-1855 Luxembourg, and registered with the Luxembourg Trade and Companies Register under number B-9248, and Clearstream Banking AG (for Clearstream Banking AG customers using Creation Accounts), registered office at 61, Mergenthalerallee, 65760 Eschborn, Germany and registered in Register B of the Amtsgericht Frankfurt am Main, Germany under number HRB 7500.