Investor FAQs

A number of exemptions from Irish dividend withholding tax (“DWT”) exist such that shareholders resident in the United States may be entitled to exemptions from DWT. Shareholders resident in the US that hold their ordinary shares through the Depository Trust Company (the “DTC”) may not be subject to DWT on distributions paid in respect of Dole plc shares. We suggest you contact the DTC to make sure all the necessary information has been provided to determine if the distributions are exempt from DWT or not. US resident shareholders in Dole plc that hold their shares outside of DTC may not be subject to DWT. We suggest you reach out to Dole plc’s transfer agent or your broker to make sure all the necessary information has been provided to determine if the distributions are exempt from DWT or not.

Please click here for more information on DWT.

Generally, yes.

Any cash distributions (including the amount of any Irish tax withheld) will generally be includible in the gross income of a US Holder as dividend income on the day actually or constructively received by the US Holder. We suggest that you seek counsel from your tax adviser on the taxability and the timing of any inclusion of the distribution.

For purposes of this discussion, a “US Holder” is a beneficial owner of our ordinary shares that is, for US federal income tax purposes, (i) an individual who is a citizen or resident of the US, (ii) a corporation (or other entity treated as a corporation for US federal income tax purposes) created in, or organized under the law of the US or any state thereof or the District of Columbia, (iii) an estate the income of which is includible in gross income for US federal income tax purposes regardless of its source, or (iv) a trust (A) the administration of which is subject to the primary supervision of a US court and which has one or more US persons who have the authority to control all substantial decisions of the trust or (B) that has otherwise validly elected to be treated as a US person under applicable US tax law. Please confirm with your tax adviser if you meet the definition of a “US Holder”.

Please consult with your tax adviser on the proper treatment of the dividend distribution, as certain distributions may be subject to a lower tax rate.

Individual shareholders who are resident or ordinarily resident in Ireland will generally be subject to income tax on gross distributions at their marginal tax rate, but may be entitled to a credit for the DWT deducted by Dole plc. Distributions will also likely be subject to the universal social charge. A charge to Irish social security taxes can also arise for such individuals on the amount of any distributions received from Dole plc. Please consult with your tax adviser the proper treatment based on your individual circumstances.

The following Irish resident shareholders will be exempt from DWT provided Dole plc or, in respect of Dole plc shares held through DTC, any qualifying intermediary appointed by Dole plc, has received from the holder of such Dole plc shares, where required, the relevant DWT forms prior to the payment of the distribution:

• Irish resident companies;
• Pension schemes approved by the Revenue Commissioners of Ireland;
• Qualifying fund managers or qualifying savings managers;
• Personal Retirement Savings Account (“PRSA”) administrators who receive the relevant distribution as income arising in respect of PRSA assets;
• Qualifying employee share ownership trusts;
• Collective investment undertakings;
• Tax-exempt charities;
• Designated brokers receiving the distribution for special portfolio investment accounts;
• Any person who is entitled to exemption from income tax under Schedule F on dividends in respect of an investment in whole or in part of payments received in respect of a civil action or from the Personal Injuries Assessment Board for damages in respect of mental or physical infirmity;
• Certain qualifying trusts established for the benefit of an incapacitated individual and/or persons in receipt of income from such a qualifying trust;
• Any person entitled to exemption to income tax under Schedule F by virtue of Section 192(2) Taxes Consolidation Act (“TCA”) 1997;
• Unit trusts to which Section 731(5)(a) TCA 1997 applies; and
• Certain Revenue-approved amateur and athletic sport bodies approved by the Revenue Commissioners of Ireland.

DWT must be deducted from distributions paid by Dole plc unless an Irish resident shareholder is entitled to an exemption and has submitted a properly completed DWT form.

Please click here for more information on DWT.

Shareholders that are “close” companies for Irish taxation purposes may, however, be subject to a 20% corporation tax surcharge on undistributed investment income. Please consult with your advisers regarding the definition and impacts of being a “close” company.

Irish stamp duty may be payable in respect of transfers of Dole plc shares depending on the manner in which the Dole plc shares are held. Dole plc has entered into arrangements with DTC to allow for Dole plc shares to be settled through the facilities of DTC.

Transfers of Dole plc shares effected by means of the transfer of book-entry interests in DTC will not be subject to Irish stamp duty. However, if you hold your Dole plc shares directly rather than beneficially through DTC or your Dole plc shares are transferred other than by means of the transfer of book-entry interests in DTC, any transfer of your Dole plc shares could be subject to Irish stamp duty. In such circumstances, while the payment of Irish stamp duty is primarily a legal obligation of the transferee, when shares are purchased on the NYSE, the purchaser will require the stamp duty to be borne by the transferor. The potential for stamp duty could adversely affect the price of your Dole plc shares which are held directly outside of DTC rather than beneficially through DTC or are transferred other than by means of the transfer of book-entry interests in DTC.

Irish capital acquisitions tax (“CAT”) could apply to a gift or inheritance of Dole plc shares, irrespective of the place of residence, ordinary residence or domicile of the parties. This is because Dole plc shares are regarded as property situated in Ireland. The person who receives the gift or inheritance has primary liability for CAT. Please consult with your tax adviser to determine the impacts based on your specific circumstances.

US backup withholding tax may apply to dividends on our ordinary shares if a US Holder (as defined above) fails to provide an accurate taxpayer identification number to the relevant transfer agent or is otherwise subject to backup withholding. Non-US Holders may be required to comply with certification and identification procedures to establish an exemption from US backup withholding tax, certifying that such holder is not a US Holder. Please consult with your tax adviser on the information and the forms needed to be provided.