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Bermuda Stock Exchange Recognized By Ireland

by Mike Godfrey, Lowtax.net, Washington
28 January, 2016

The Bermuda Stock Exchange has been named by the Irish tax authority as a recognized stock exchange for the purposes of Section 64 of Ireland's Taxes Consolidation Act 1997.

In general, tax at the standard rate of income tax is required to be withheld from payments of Irish source interest. However, an exemption from withholding on interest payments exists under Section 64 of the Taxes Consolidation Act, 1997, for quoted Eurobonds issued by a body corporate (such as an Issuer) that are interest bearing and quoted on a recognized stock exchange.

Any interest paid on such quoted Eurobonds can be paid free of withholding tax, provided that the person by or through whom the payment is made is not in Ireland; or the payment is made by or through a person in Ireland, and either: the quoted Eurobond is held in a clearing system recognized by the Irish Revenue Commissioners, or the person who is the beneficial owner of the quoted Eurobond and who is beneficially entitled to the interest is not resident in Ireland and has made a declaration to a relevant person (such as an Irish paying agent) in the prescribed form.

The BSX CCO, James McKirdy, commented: "Receiving confirmation by the Irish tax authorities that the BSX is considered a recognized stock exchange for the purposes of Section 64 of Ireland's Taxes Consolidation Act 1997 is a very positive step forward for the BSX international debt listing platform."

"BSX has seen steady growth in its international debt listing business over the last 18 months with over 50 new debt listings. This confirmation is an excellent way to begin 2016."

The BSX has also received designations, recognitions, and affiliations from a number of bodies, including: the Bermuda Monetary Authority, the US Securities and Exchange Commission, the World Federation of Exchanges, the International Organization of Securities Commissions, the Australian Tax Office, the UK's Financial Conduct Authority, HM Revenue & Customs, and the Canadian Ministry of Finance.


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