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Dividend Withholding Tax Information

Eaton Corporation plc has established tax residence in Ireland, and as such, dividends are considered Irish source income and Irish dividend withholding tax (“DWT") rules apply. Beginning with the dividend payable on March 22, 2013, payments will be subject to an Irish withholding tax of 20% of the amount of each dividend unless the shareholder that is beneficially entitled to the dividend is a resident of the United States or a resident of a country listed as a “relevant territory”, and has ensured that the required information is on file with their broker, bank, qualifying intermediary or transfer agent (see below for more detail). With these rules, the vast majority of Eaton’s shareholders and beneficial owners are entitled to an exemption from DWT. The full list of relevant territories can be found by clicking on this link: Relevant Territories.pdf

 

Shareholders and beneficial owners who are not residents of a relevant territory are generally subject to DWT. There are limited exceptions, however, and if you are not a resident of a relevant territory, you should consult your tax advisor.

 

Beneficial U.S. Shareholder DWT Exemption Requirements:

U.S. shareholders that are beneficial owners of Eaton Corporation plc shares held in the Depository Trust Company (“DTC”) through a bank, broker or qualifying intermediary, must have a valid U.S. address on the records of their bank, broker or qualifying intermediary on the record date of the dividend to be exempt from DWT.

 

Registered U.S. Shareholder DWT Exemption Requirements:

U.S. shareholders with shares registered directly with Eaton’s transfer agent, Broadridge Corporate Issuer Solutions, Inc. (“Broadridge”), that have a U.S. address on file and held shares of Eaton Corporation immediately prior to the completion of the Cooper transaction on November 30, 2012 will be exempt from DWT for a period of one year beginning from the shareholder vote on October 26, 2012. Beginning October 26, 2013, these U.S. registered holders will be required to have an IRS Form W-9 on file with Broadridge to continue to be exempt from DWT. Note that effective January 1, 2018, all U.S. registered holders will be required to file a valid Irish Non-Resident Form V2 with Globe Tax Services Inc. (“Globetax”) to be exempt from DWT. The Irish Non-Resident Form V2 will need to either be certified by the U.S. tax authorities or accompanied by a U.S. Certification of Residence (Form 6166).

 

U.S. registered shareholders who held shares in Cooper Industries plc immediately prior to its acquisition by Eaton Corporation plc on November 30, 2012, may continue to rely on forms previously filed with Eaton’s former transfer agent, Computershare Trust Company, N.A. (“Computershare”) to the extent those forms are still current and have not expired. Note that effective January 1, 2018, all U.S. registered holders will be required to file a valid Irish Non-Resident Form V2 with GlobeTax to be exempt from DWT. The Irish Non-Resident Form V2 will need to either be certified by the U.S. tax authorities or accompanied by a U.S. Certification of Residence (Form 6166).

 

U.S. registered shareholders that became shareholders of Eaton Corporation plc after the completion of the Cooper transaction on November 30, 2012 are required to file a valid Irish Non-Resident Form V2 with GlobeTax by the dividend record date to be exempt from DWT. The Irish Non-Resident Form V2 will need to either be certified by the U.S. tax authorities or accompanied by a U.S. Certification of Residence (Form 6166).

 

To obtain Form 6166 from the IRS, U.S. shareholders should file Form 8802, Application for United States Residency Certification, with the IRS at least 45 days before the Form 6166 is needed.

 

Non-U.S. Shareholder DWT Exemption Requirements

 

If you are a shareholder who is resident in a relevant territory, other than the U.S., and were a shareholder of Eaton Corporation immediately prior to the completion of the Cooper transaction on November 30, 2012, you will be exempt from DWT for a period of one year beginning from the shareholder vote on October 26, 2012. Beginning October 26, 2013, you will need to file a valid Irish Non-Resident Form V2 with your broker, bank, qualifying intermediary or GlobeTax to be exempt from DWT.  Please note that the form must be certified by the tax authority of the country in which you are a resident.

 

Shareholders in relevant territories who held shares in Cooper Industries plc immediately prior to its acquisition by Eaton Corporation plc on November 30, 2012, may continue to rely on forms previously filed with Computershare, Cooper Industries plc, Cooper Industries plc’s qualifying intermediary, or their bank or broker to the extent those forms are still current and have not expired.

 

Shareholders in relevant territories that became shareholders of Eaton Corporation plc after the completion of the Cooper transaction on November 30, 2012 are required to file a valid Irish Non-Resident Form V2 with their broker, bank, qualifying intermediary or GlobeTax by the dividend record date to be exempt from DWT. Please note that the form must be certified by the tax authority of the country in which you are a resident.

 

For your convenience, attached below are Irish Dividend Withholding Tax Forms (Forms V2) and Application for United States Residency Certification (Form 8802):

 

-          Non-Resident Form V2A-Exemption from DWT for a qualifying non-resident individual.pdf

-          Non-Resident Form V2B-Exemption from DWT for a qualifying non-resident company.pdf

-          Non-Resident Form V2C-Exemption from DWT for a qualifying non-resident person (not being and individual or company).pdf

-          Application for United States Residency Certification (Form 8802)