Holders of ADRs evidencing ADSs are generally eligible for all dividends or other entitlements attaching to the underlying shares of Vodafone Group Plc and receive all cash dividends in US dollars.
The US and the UK previously agreed a Double Taxation Convention which entered into force in 1980 (the "Old Treaty") and recently agreed a replacement Double Taxation Convention which entered into force on 31 March 2003 (the "New Treaty"). The New Treaty is generally effective in respect of taxes withheld at source for amounts paid or credited on or after 1 May 2003. Other provisions of the New Treaty, however, took effect for UK purposes for individuals on 6 April 2003 (1 April 2003 for UK companies) and, will take effect for US purposes, on 1 January 2004. The rules of the Old Treaty will remain applicable until these effective dates. However, a taxpayer may elect to have the Old Treaty apply in its entirety for a period of twelve months after the applicable effective dates of the New Treaty.
Under the Old Treaty, a US holder (other than corporations who together with associated corporations hold more than 10% of the voting shares of Vodafone Group Plc) is in principle entitled to receive a tax credit from the UK Inland Revenue. However, as the required withholding tax equals the UK tax credit, no credit is repayable.
Under the New Treaty, a US holder will not be entitled to a tax credit from the UK Inland Revenue. However, a dividend received by a US holder will generally not be subject to any withholding tax by the UK.
Dividends and any related UK tax credit available are generally ordinary income to the holder for Federal income tax purposes. ADS holders unsure of their tax position should consult their independent tax adviser.
- ADS Holder FAQs
A list of questions frequently asked by ADS holders including information about the Company's Dividend Reinvestment Plan - Global BuyDIRECT. - Dividend Reinvestment Plan (DRIP)
The DRIP allows holders of ordinary shares to use their cash dividends to acquire additional shares in the Company through a low cost dealing arrangement.