Medtronic 2016 Annual Report Download - page 38
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Table of Contents
35
Irish Taxes Applicable to U.S. Holders
Dividends paid by Medtronic will generally be subject to Irish dividend withholding tax at the standard rate of income tax (currently
20 percent) unless an exemption applies.
Dividends paid to U.S. residents will not be subject to Irish dividend withholding tax provided that:
• in the case of a beneficial owner of Medtronic shares held in the Depository Trust Company (DTC), the address of the
beneficial owner in the records of his or her broker is in the United States and this information is provided by the broker
to the Company’s qualifying intermediary; or
• in the case of a record owner, the record owner has provided to the Company’s transfer agent a valid U.S Certification
of Residence (Form 6166) or valid Irish Non-Resident Form V2.
Irish income tax may also arise with respect to dividends paid on Medtronic’s ordinary shares. A U.S. resident who meets one of
the exemptions from dividend withholding tax described above and who does not hold Medtronic shares through a branch or
agency in Ireland through which a trade is carried on generally will not have any Irish income tax liability on a dividend paid by
Medtronic. In addition, if a U.S. shareholder is subject to the dividend withholding tax, the withholding payment discharges any
Irish income tax liability, provided the shareholder furnishes to the Irish Revenue authorities a statement of the dividend withholding
tax imposed.
While the U.S./Ireland Double Tax Treaty contains provisions regarding withholding, due to the wide scope of the exemptions
from dividend withholding tax available under Irish domestic law, it would generally be unnecessary for a U.S. resident shareholder
to rely on the treaty provisions.