Roundtable Discussion; The Future of Mineral Sands. Watch the video here.
Email address for Majid ?
I have a long standing, 7 figure holding in i3E, which is held via Interactive Brokers, with whom I have signed up for their stock lending programme. On Tuesday (27 June), more than 1/2 my i3E holding was lent out => read in to this what you will - leaky ship / well researched shorter. Obviously, I am not happy with the dividend cut and share price dump. What is interesting is that IB are charging over 15% pa for lending my shares out - I know this as I get 1/2 of this paid to me by IB.
What is interesting about LOAM (and also ORA Capital - the Richard Griffiths vehicle) is the amount of money they have made from the July 2021 loan notes, which will compensate for any losses / low profits on their equity position.
In the RNS yesterday, it mentions "..There will also be a one off interest charge of approximately £4.7m linked to the Group's loan notes that were executed in July 2021, based on a successful conclusion to the Samsung litigation."
The loan notes had a nominal value of GBP 4.5m, but were issued at 70% (i.e. the investors paid GBP 3.15m) and were also subject to an arrangement fee of 1.4% of the nominal (i.e. the investors received GBP 0.063m upfront).
The loan notes are repayable at 100% of nominal after 3 years in July 2023 (next year - shortly after Samsung pays the 2nd instalment) and there is a 105% bonus of the nominal for a successful litigation (i.e an additional GBP 4.725M - the approx GBP 4.7m referred to in the RNS).
So for an initial net investment of GBP 3.087m, the payment in July next year will be GBP 9.225m => 2.99 times the original investment. Not bad for "non-dilutive" loan notes ! The returns here are much better than the litigation funder is getting.
Hello again Matthew125,
I decided to chase the Swiss WHT so used the FTA's "Contact Form" to enquire about status of my claim. Got an email back overnight after 2 day, which reads:
"Thank you for your E-mail. Your claim has been properly uploaded on February 8, 2022. It was given the Case-ID .
At a very preliminary glance, it seems to be in order. However, we will not be able to treat your claim right away:
Due to a substantial backlog we currently need about six months (from the date of upload) until we process the claims.
Thank you for your understanding and patience."
Last year, it took about 4 months to get processed & paid.
Hi,
Having successfully applied from Hong Kong (received payment from Swiss Tax Office in July) for calendar 2020, my broker - Interactive Brokers - supplied 2 forms for each of the 6 dividends => a Tax Voucher (which came from IB in the US effectively stating that the w/h tax was paid by IB); and a Dividend Distribution credit advice (which came from IB UK, but with a Swiss - in Zug - address). I had to pay IB for each pair of forms - CHF 10.
Hi Ezio. Auditor,
The Swiss Tax office will give you a File Number to use in future applications, once they have processed your first application. I did my first one earlier this year; got paid in July; and received a File Number back with the confirmation. So leave box blank for this (first) application.
Hi rbrand,
Interactive Brokers is a US broker, though they do have a UK sub just like they have a HK sub. Have not come across HK subs of UK brokers. Most people here trade HK, China and US stocks.
I am slightly bemused by all the talk here about why Ferrexpo is a Swiss company - very simple, our majority shareholder is a Swiss resident and is not subject to the W/H tax on his dividends.
I think a lot of people on this board do not invest outside the UK and thus do not come across W/H tax. For example, the standard rate for the US is actually 30% - almost as much as the 35% in Switzerland - before the effect of double tax treaties. So as HK has no treaty with the US, I suffer the full 30% w/h tax for dividends from the US, but the 35% Swiss rate is reduced to 10% because HK has a tax treaty with Switzerland. For UK investors, the US rate of 30% is reduced to 15%.
Interactive Brokers - their Hong Kong subsidiary. In nominee name.
Have received a letter now from the Swiss FTA confirming the transfer, that I received, and giving me a File Number (FTA-ID) to be used in any future claims.
I posted back in March that I had submitted a claim direct to the Swiss Federal Tax Administration to claim back W/H tax on the 6 dividends I received in calendar 2020.
As I live in Hong Kong, I was claiming the difference between the standard 35% withheld and the 10% rate in the HK / Swiss tax treaty.
Just received a full payment (just shy of CHF 6,000) this morning in my CHF bank a/c. It has taken 4 1/2 months from mid March, but the FTA have paid up. My only cash cost was the CHF 90 I paid to my broker for dividend vouchers, plus a lot of time & effort doing the forms and getting the required information & supporting docs.
So it can be done !
You have to remember that the LSE runs on T + 2 for settlement => you buy today and your trade settles 2 business days later. At that point you are on the register. So if the company quote a date that you must be on the register for the dividend, then you have to buy 2 business days before this date . The date that is 1 business day before is then known as the XD date, when you are too late, as your trade will settle 1 business day too late, on the far side of the date stated by the company.
They will pay the reclaimed w/h tax in CHF. If your bank can handle a foreign currency payment destined for a GBP denominated a/c, then presumably no problem. You still need to make sure you can provide the BIC & IBAN.
Sorry, one last crucial point to note.
The Swiss FTA will only refund in CHF and you must have a CHF bank a/c with ideally the BIC and IBAN details. I had an existing CHF savings a/c in HK, but because BIC / IBAN are not used in HK - only SWIFT - I specially opened a CHF currency savings a/c with my Jersey based bank, who of course can provide a BIC / IBAN being in the UK banking system.
Hello,
Interesting that there is a specific form for the UK. The top box of Form 60 is for insertion of the specific country having the DTA with Switzerland. Form 60 allows for 3 calendar years of claims as well. Given the need to get a Tax residency certificate in HK, I have opted to do the form annually - plus not much space to write all the dividend details down and there were a total of 6 in calendar 2020.
Here's the web link for the page to get the FX rates:
www.ictax.admin.ch/extern/en.html#/ratelist
When you get there, click on "Course listings 2020" on the right.
Then look at the top box on the left for Currencies. Insert the required date and GBP.
Hello,
I am with Interactive Brokers - the HK subsidiary. I assume the shares are held in IB's nominee name.
The Dividend Statements and accompanying Tax Vouchers are special produced (and cost CHF 15 per dividend). They are headed up Interactive Brokers LLC - the holding company - in Greenwich, USA, but are signed by Interactive Brokers (UK) Ltd [the shares are of course London listed] but refer to IBKR Financial Services AG as the custody provider. The latter is a Swiss sub of IB and the dividend statements are stated as being issued in Zug.
HK has a lot of DTAs as it is in no way a tax haven. I make use of the DTAs with Canada (for redoing w/h tax on divs from 25% to 15%) and the UK. The Swiss DTA was signed 10/2011 and has been in power since 12/2012. Likewise the Canadian DTA since Oct/2013 and the UK DTA since 12/2010. There are DTAs with major EU countries such as France, Italy, Belgium, Spain, Holland, Austria and Finland.