Relief at source - eligibility, documentation, deadlines - Irish equities
Who can obtain relief at source?
Tax relief at source on dividends from Irish equities is available through Clearstream Banking, provided that the below conditions are met:
- A segregated account is opened by Clearstream Banking customers in order to exclusively hold Irish equities distributing dividends that are eligible for a tax exemption at source (the “segregated account”), and
- Relevant tax documentation is provided by Clearstream Banking customers to certify this segregated account before the transfer of those Irish equities to the segregated account, and
- Clearstream Banking customer is either:
- the final beneficial owner of the dividends paid from the Irish equities and is a qualifying non-resident person or an excluded Irish person, or
- a Qualified Intermediary (QI), authorized by Irish Revenue Commissioners, and holds the Irish equities, directly or through a chain of QIs, on behalf of final beneficial owners that are either qualifying non-resident persons or excluded Irish persons
After the receipt and validation of the tax documentation, the segregated account will be flagged as “exempt” in Clearstream Banking and all dividends from Irish domestic equities will be paid gross on this account. However, please note that any distributions by Irish REITs from their property income will be paid net on this account.
Documentation requirements
In order to benefit from tax relief at source on dividends from Irish equities, customers must ensure to provide Clearstream Banking with the following documents before the transfer of the Irish equities (distributing dividends eligible for tax exemption at source) on the segregated account. The related templates of the forms are available on our Tax forms to use section.
For all customers applying for tax relief at source on dividends from Irish equities:
- One-time certificate for Irish domestic equities, in the name of the Clearstream Banking customer
In addition, for Clearstream Banking customers that are Qualified Intermediaries,
- A copy of the document delivered by the Irish Revenue Commissioners and proving the QI status
- Any other document or information that may be required by Irish Revenue Commissioners upon request
Important note: QI customers are responsible to ensure that the Irish equities transferred on the segregated account opened with Clearstream Banking are only held on behalf of persons that are entitled to a tax exemption at source on Irish dividends, according to Irish Revenue Commissioners requirements.
In addition, for Clearstream Banking customers that are the final beneficial owners and qualifying non-resident persons:
- A Qualifying Non-Resident Form V2A or V2B or V2C, in the name of the final beneficial owner,
- A Power of Attorney, only if a third party is completing the Non-Resident form on behalf of the final beneficial owner
In addition, for Clearstream Banking customers that are the final beneficial owners and excluded Irish persons:
- A declaration of Irish person, depending on the declarant’s status:
- A Resident Form V3, in the name of the final beneficial owner, or
- A declaration to be made by an Irish Exempt Unit Trust, for the purpose of Exemption from Dividend Withholding Tax (DWT), or
- A declaration to be made by an Irish Personal Retirement Savings Account (PRSA) Administrator for the purpose of Exemption from Dividend Withholding Tax (DWT)
- A Power of Attorney, only if a third party is completing the declaration of Irish person on behalf of the final beneficial owner
Validity of the documents
Certificate | Validity |
One-time certificate for Irish domestic equities | Valid until revoked, unless there is a change in circumstances |
A copy of the document delivered by the Irish Revenue Commissioners to prove QI status | Valid until revoked, unless there is a change in circumstances |
Qualifying Non-Residents Forms V2A/V2B/V2C | Valid from the date of issue until 31 December in the fifth year following the year in which the certificate was issued. |
Declaration of Irish person (for excluded Irish persons) | Valid until the excluded Irish person notifies Clearstream Banking that they have ceased to be an excluded person. |
Deadlines for receipt of documents
Any of the above-mentioned tax documentation should be received by Clearstream Banking before transferring the Irish equities (distributing dividends eligible for tax exemption at source) on the segregated account for exempted persons.