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It would be good for the payment of the final dividend to be pre re-domiciliation, which if the re-domiciliation takes place in May 2024 as projected, would mean the AGM being brought forward to soon after the final results. In addition how about the payment of a special dividend marking the transfer to the UK market. Both would save Spanish WHT.
Even for non SIPP/ISA holders - "Reclaiming dividend tax from Spain is not made easy and feels awkward. I understood that in some cases you will also need a local Spanish tax representative to file the reclaim for you." Source European Dividend Growth Investor". Another reason to avoid domicilation in Spain.
Those that hold shares through a SIPP or ISA should vote against the proposal.
I also wonder how the proposal squares with the UKLA rules not to act to the disadvantage of any one group of shareholders. Whether the impact of personal circumstances would carry weight I do not know.
A copy of the email I sent to 4Ccommunications:
Dear Carina
A consequence of the proposal above is that withholding tax (WHT) of 19% will be deducted from dividends paid by Atalaya. This withholding tax is NOT reclaimable by UK residents if they hold their shares in a SIPP or ISA. It is understood from past correspondance that this applies to the majority of individual UK holders of Atalaya. As a consequence the proposal will lead to the value of future dividends being reduced by 19% at a stroke which clearly is very significant.
It is apparent from the presentation yesterday that no thought has been given to this impact by management. I gather there were a number of questions on the issue. This is particularly of concern that when a similar issue arose with the Cypriot equivalent WHT management were able to persuade the Cypriot authorities not to deduct WHT I think on the grounds that most individual shareholders held the stock through SIPPs or ISAs. Atalaya now take a backward step in this respect.
I expect the proposal will be approved, as corporate holders, the majority, do not suffer this impact. A number of individual holders will consequently vote with their feet.
I urge management to consider what can be done. Are there ways to alleviate the impact: for example through negotiation with the Spanish tax authorities or are their exemptions in place for payments to UK Pension Funds?
I would be grateful if you would take this matter up with management.
Following todays call, it becomes clear that all who hold Atalaya through SIPP or ISA (most individual UK holders) will be subjected to non recoverable WHT of 19% on dividends as a result of re-domiciliation to Spain. I for one will be voting against the proposal. Not happy with management's response of ignoring the issue.
Whalebone from the 2021 results
"The Dividend Policy will make an annual pay-out of 30 - 50% of free cash flow generated during the applicable financial year, and be paid in two half-yearly instalments that will be announced in conjunction with future interim and full year results."
Broadly I would say RNS's are issued by TXP at reasonable times. Their purpose is to disseminate price sensitive information. Just confirming they are on target against a previously announced plan does not pass the test for an RNS. Which is where social media comes in. Spudding Royston is more borderline - previously announced but more of a step change.
Disappointing margins at the moment. My slightly RTG view for the next 12 months is that Copper prices will return to $4 quite quickly. The AISC will hopefully fall to $3 by next July when Solar Power is commissioned and a $1 margin per lb is good to warrant a market price of £4 using a six year cap factor (my workings!). And thats without ELIX.