Ryanair 2012 Annual Report Download - page 118

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TAXATION
Irish Tax Considerations
The following is a discussion of certain Irish tax consequences of the purchase, ownership and
disposition of Ordinary Shares or ADSs. This discussion is based upon tax laws and practice of Ireland at the
date of this document, which are subject to change, possibly with retroactive effect. Particular rules may apply
to certain classes of taxpayers (such as dealers in securities) and this discussion does not purport to deal with the
tax consequences of purchase, ownership or disposition of the relevant securities for all categories of investors.
The discussion is intended only as a general guide based on current Irish law and practice and is not
intended to be, nor should it be considered to be, legal or tax advice to any particular investor or stockholder.
Accordingly, current stockholders or potential investors should satisfy themselves as to the overall tax
consequences by consulting their own tax advisers.
Dividends. If Ryanair Holdings pays dividends or makes other relevant distributions, the following is
relevant:
Withholding Tax. Unless exempted, a withholding at the standard rate of income tax (currently 20%)
will apply to dividends or other relevant distributions paid by an Irish resident company. The withholding tax
requirement will not apply to distributions paid to certain categories of Irish resident stockholders or to
distributions paid to certain categories of non-resident stockholders.
The following Irish resident stockholders are exempt from withholding if they make to the Company,
in advance of payment of any relevant distribution, an appropriate declaration of entitlement to exemption:
Irish resident companies;
Pension schemes approved by the Irish Revenue Commissioners (―Irish Revenue‖);
Qualifying fund managers or qualifying savings managers;
Personal Retirement Savings Account (―PRSA‖) administrators who receive the relevant distribution as
income arising in respect of PRSA assets;
Qualifying employee share ownership trusts;
Collective investment undertakings;
Tax-exempt charities;
Designated brokers receiving the distribution for special portfolio investment accounts;
Any person who is entitled to exemption from income tax under Schedule F on dividends in respect of
an investment in whole or in part of payments received in respect of a civil action or from the
Personal Injuries Assessment Board for damages in respect of mental or physical infirmity;
Certain qualifying trusts established for the benefit of an incapacitated individual and/or persons in
receipt of income from such a qualifying trust;
Any person entitled to exemption to income tax under Schedule F by virtue of Section 192(2) Taxes
Consolidation Act (―TCA‖) 1997;
Unit trusts to which Section 731(5)(a) TCA 1997 applies; and
Certain Irish Revenue-approved amateur and athletic sport bodies.
The following non-resident stockholders are exempt from withholding if they make to the Company, in
advance of payment of any dividend, an appropriate declaration of entitlement to exemption: