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

22.02.2023

Withholding Tax - Equities

Standard rate of withholding tax:

0% - 47%

Preliminary requirements / Holding restrictions:

No

Overview

Exemption from tax or relief at source from withholding tax on dividends from Australian equities is available through Clearstream Banking 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 equities as follows:

Eligible beneficial owners

Rate applicable at source

Tax-exempt beneficial owners

0%

Residents of Australia

0%

Residents of a Double Taxation Treaty (DTT) country

Tax treaty rate or 30%,
 whichever is lower

Non-residents of Australia (not tax-exempt or DTT country)

30%

Clearstream Banking 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 Banking applies, by default, withholding tax at source at 15% on dividend payments for Australian equities.

If such formal request has not been received by Clearstream Banking by the set deadline, Clearstream Banking 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 Banking in order to be eligible for the 0% rate. Undisclosed Australian residents may, upon request of the customer, be subject to the maximum withholding tax rate (47%).

Documentation requirements

For relief at source from withholding tax on dividends from Australian equities, 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 Banking'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 equities must be received by Clearstream Banking by the following dates:

Document

Deadline for receipt by Clearstream Banking

Request for Application of a Reduced Rate of Australian Withholding Tax on Dividends

Three business days before the first dividend payment by 10:00 CET.

Breakdown of Holdings

Three business days before each relevant dividend payment by 10:00 CET.

Certificate of Exemption

Three business days before the first dividend payment by 10:00 CET.

Certificate of Residence

Upon request.

List of Beneficial Owners - Australian Securities

Upon request.

Withholding Tax - MITs

Standard rate of withholding tax:

0% - 47%

Preliminary requirements / Holding restrictions:

No

Overview

Exemption from tax or relief at source from withholding tax on income from MIT distributions is available through Clearstream Banking 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:

Eligible beneficial owners

Rate applicable at source on...

...interest component

...unfranked component

Tax-exempt beneficial owners

0%

0%

Residents of Australia

0%

0%

Residents of a Double Taxation Treaty (DTT) country

DTT rate or 10%,
 whichever is lower

DTT rate or 30%,
 whichever is lower

Non-residents of Australia (not tax-exempt or DTT resident)

10%

30%

 Clearstream Banking 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 Banking applies, by default, withholding tax at source at 15% on dividend payments for Australian equities.

If such formal request has not been received by Clearstream Banking by the set deadline, Clearstream Banking 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 Banking in order to be eligible for the 0% rate. Undisclosed Australian residents may, upon request of the customer, 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 Banking'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.alian 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 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.

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 Banking by the following dates:

Document

Deadline for receipt by Clearstream Banking

Request for Application of a Reduced Rate of Australian Withholding Tax on Dividends

Three business days before the first dividend payment by 10:00 CET.

Breakdown of Holdings

Three business days before each relevant dividend payment by 10:00 CET.

Certificate of Exemption

Three business days before the first dividend payment by 10:00 CET.

Certificate of Residence

Upon request.

List of Beneficial Owners - Australian Securities

Upon request.

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