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This blog relates solely to former Eircom shareholders who acquired their Vodafone ordinary shares in exchange for Eircom shares in 2001. It sets out the tax position in respect of the Return of Value and share consolidation which was effected on 21 February 2014. September 2nd 2013 seen the confirmation of the sale of the US Group of Vodafone to Verizon Communications Inc. Vodafone also announced that it intended to carry out a return of value to the shareholders in part cash and Verizon Communications shares. The value being returned to Vodafone was to be the issuing of B Shares (“Capital Option”) or C Shares (“Income Option”) to shareholders. Opting for the B Shares (Capital Option) means that the return of value will be subject to capital gains tax treatment. Opting for the C Shares (Income Option) means the return of value will be subject to income tax treatment. The terms of the Scheme are as follows: Under the terms of the Return of Value and share consolidation, Vodafone shareholders received the following:
  • 6 New Vodafone Ordinary shares for every 11 existing Vodafone ordinary shares
  • 0.0263001 Verizon Shares for every Vodafone Share
Cash of €0.3585437 for every Vodafone Share (US$0.4928005 converted at a rate of €1 to $1.37445 Capital Gains Tax and former Eircom Shareholders: Those who received their shares in exchange for Eircom shares in 2001 will not be liable under Capital Gains Tax as the following example shows
Example CGT Computation of shareholder who opted for the Capital Option and Sale of the Verizon Shares: An Individual with 1000 Vodafone Shares received the following:
Cash (1000 x €0.3585437)					€358.54
26 Verizon Shares (Price per share €34.0835897)			€886
545 New Vodafone Ordinary Shares: Cash in respect of fractional entitlements in Vodafone Ordinary Shares and Verizon shares (assumed Nil in this example).. Computation Amount of Consideration (Return of Value) on 1000 Vodafone Ordinary Shares Cash € 358 Verizon Share Value € 886 Total Consideration €1,244 Less Part of Base Cost applicable to this part-disposal Base Cost 1,965 Net Loss (721) Income Tax Treatment Those who choose the Option C scheme or didn’t specify will have received a dividend consisting of cash and Verizon Communications shares.  This dividend will be taxable in the same way as all previous Vodafone dividends. The amount of the dividend that each individual should declare for income tax purposes is the sum of the cash actually received (€358 based on example 1 above) and the market value of the Verizon Consideration Share Entitlement received (€886 as per the same example1). Individuals aged 65 years of age or over can claim exemption from income tax in 2014 if their total income for the year, including pensions and other income (such as Vodafone /Verizon Dividends), is less than:
  • €18,000, if single, widowed or a surviving civil partner, or
  • €36,000, if married or in a civil partnership.
Individuals taxed through the PAYE System Individuals who pay tax through the PAYE system and have net assessable non-PAYE income of less than €3,174, can have the tax due on the non-PAYE income collected by offset against their tax credits either by: Where Using PAYE Anytime – Entering in the “UK Dividends” box, the amount of the payment received (€1,244 in example 1 above). [If not registered for PAYE Anytime, a PAYE taxpayer can do so by logging on to and selecting ‘Register for PAYE Anytime’] or by  contacting their Revenue office – and providing details of the dividends. Revenue will then reduce the PAYE tax credits by the amount of the dividend income and will issue a new Tax Credit Certificate. Revenue will also send a new notice to employers showing the reduced tax credits to be applied in payroll. In this way the tax due on the Vodafone income will be collected from salary/wages through the PAYE system. Individuals taxed through the Self-Assessing System Individuals who are “chargeable persons” subject to Self-Assessment are required to include all their assessable income on their annual tax returns. Individuals who in addition to paying tax through the PAYE system, have net assessable non-PAYE income of €3,174 or more in any year of assessment are chargeable persons and must complete a Form 11. The amount of the Vodafone income (€1,244 in example 1) should be included in the Form 11. The dividends are liable to Income tax and USC, and may also be liable to PRSI depending on taxpayers’ personal circumstances. If you have any further questions relating to this or any other matter please contact us today or call 01-6424208