Relief at source – eligibility, documentation, deadline –ETFs, Managed Investment Trusts (MITs) - Australia - CFCL

Withholding Tax - ETFs

Overview

Exemption from tax or relief at source from withholding tax on dividends from Australian equities is available through Clearstream Fund Centre for all types of beneficial owners recognised in Australia.

Who can obtain relief at source?

Beneficial owners can obtain an exemption from tax or relief at source from withholding tax on dividend payments on Australian ETFs as follows:

Clearstream Fund Centre provides a simplified procedure whereby, upon receipt of a duly completed and signed Request for Application of a Reduced Rate of Australian Withholding Tax on Dividends, Clearstream Fund Centre applies, by default, withholding tax at source at 15% on dividend payments for Australian ETFs.

If such formal request has not been received by Clearstream Fund Centre by the set deadline, Clearstream Fund Centre will consider that the securities are held by non-resident beneficial owners and will apply the 30% withholding tax rate by default.

Australian residents must provide their Tax File Number (TFN) or Australian Business Number (ABN) to Clearstream Fund Centre in order to be eligible for the 0% rate. Undisclosed Australian residents may, upon request of the client, be subject to the maximum withholding tax rate (47%).

Documentation requirements

For relief at source from withholding tax on dividends from Australian ETFs, there are different documentation requirements depending on the type of beneficial owner, as follows:

• Non-residents of Australia, other than tax-exempt entities or residents of a DTT country:
  - No certification is required. Clearstream Fund Centre's non-resident withholding tax rate of 30% is applied automatically by default.
• Tax-exempt entities:
  - Request for Application of a Reduced Rate of Australian Withholding Tax on Dividends;
  - Breakdown of Holdings;
  - Certificate of Exemption;
    and upon request;
  - List of Beneficial Owners - Australian Securities.
• Residents of a Double Taxation Treaty (DTT) country:
  For beneficial owners subject to a 15% treaty rate:
  - Request for Application of a Reduced Rate of Australian Withholding Tax on Dividends;
    and upon request;
  - List of Beneficial Owners - Australian Securities;
  - Certificate of Residence.
• For beneficial owners subject to a reduced tax treaty rate other than 15%
  - Request for Application of a Reduced Rate of Australian Withholding Tax on Dividends;
  - Breakdown of Holdings;
    and, upon request
  - List of Beneficial Owners - Australian Securities
  - Certificate of Residence
• Residents of Australia:
  For disclosed Australian residents:
  - Request for Application of a Reduced Rate of Australian Withholding Tax on Dividends;
  - Breakdown of Holdings (including ABN/TFN);
    and, upon request:
  - List of Beneficial Owners - Australian Securities;
  - Certificate of Residence
  
  For undisclosed Australian residents:
  - Breakdown of Holdings
   

Deadline for receipt of documents

Documentation for relief at source from withholding tax on dividends from Australian ETFs must be received by Clearstream Fund Centre by the following dates:

Withholding Tax - MITs

Overview

Exemption from tax or relief at source from withholding tax on income from MIT distributions is available through Clearstream Fund Centre for the following distribution components only:

• Unfranked dividend components;
• Interest components.

Other types of components are paid by default at the rates stated in the qualifying Notices issued by the MIT.

Who can obtain relief at source?

Beneficial owners can obtain an exemption from tax or relief at source from withholding tax on unfranked and interest components of MIT distributions as follows:

Clearstream Fund Centre provides a simplified procedure whereby, upon receipt of a duly completed and signed Request for Application of a Reduced Rate of Australian Withholding Tax on Dividends, Clearstream Fund Centre applies, by default, withholding tax at source at 15% on dividend payments for Australian Vestima fund securities.

If such formal request has not been received by Clearstream Fund Centre by the set deadline, Clearstream Fund Centre will consider that the Vestima fund securities are held by non-resident beneficial owners and will apply the 30% withholding tax rate by default.

Australian residents must provide their Tax File Number (TFN) or Australian Business Number (ABN) to Clearstream Fund Centre in order to be eligible for the 0% rate. Undisclosed Australian residents may, upon request of the client, be subject to the maximum withholding tax rate (47%).

Documentation requirements

For relief at source from withholding tax on income from MIT distributions, there are different documentation requirements depending on the type of beneficial owner, as follows:

• Non-residents of Australia, other than a tax-exempt entities or residents of a DTT country:
  - No certification is required. Clearstream Fund Centre's non-resident withholding tax rate of 30% is applied automatically by default.
• Tax-exempt entities:
  - Request for Application of a Reduced Rate of Australian Withholding Tax on Dividends;
  - Breakdown of Holdings;
  - Certificate of Exemption;
    and, upon request:
  - List of Beneficial Owners - Australian Vestima fund securities. Withholding Tax on Dividends;

Residents of a Double Taxation Treaty (DTT) country:

• For beneficial owners subject to a 15% treaty rate:
  - Request for Application of a Reduced Rate of Australian Withholding Tax on Dividends;
    and upon request;
  - List of Beneficial Owners - Australian Vestima fund securities;
  - Certificate of Residence.
   
• For beneficial owners subject to a reduced tax treaty rate other than 15%:
  - Request for Application of a Reduced Rate of Australian Withholding Tax on Dividends;
  - Breakdown of Holdings;
    and, upon request:
  - List of Beneficial Owners - Australian Vestima fund securities;
  - Certificate of Residence.
• Residents of Australia:
  For disclosed Australian residents:
  - Request for Application of a Reduced Rate of Australian Withholding Tax on Dividends;
  - Breakdown of Holdings (including ABN/TFN);
    and upon request;
  - List of Beneficial Owners - Australian Vestima fund securities;
  - Certificate of Residence.
  
  For undisclosed Australian residents:
  - Breakdown of Holdings.

Note: Relief at source is currently available only for “unfranked dividend” and “interest” components of MIT distributions.

Deadline for receipt of documents

To obtain relief at source from withholding tax on income from MIT distributions, documentation must be received by Clearstream Fund Centre by the following dates:

Note: Relief at source is currently available only for “unfranked” and “interest” components of MIT distributions.