Dividend withholding tax differences in multiple listings

vikkiew

A French company share is listed on 3 markets: local French EURONEXT, our own LSE and American NYSE. For simplicity assume the dividend is the same 100 for all 3 listings, that there is no currency or foreign exchange fees to worry about. Assume the account has no WHT or other double tax treaty reduction agreements with France, however it is a UK tax wrapper, let's say SIPP.

How much of the 100 from the EURONEXT listed payment makes it to the UK SIPP?

How much of the 100 from the LSE listed payment makes it to the UK SIPP?

How much of the 100 from the NYSE listed payment makes it to the UK SIPP?

Do they all get the 30% cut from the French?Is the NYSE listed guaranteed to be the most inefficient due to additional ADR custody fees? 

Jeremy535897

The French deduct 30% WHT from French company dividends paid to non French residents. The stock exchange on which it is listed is irrelevant, so far as I am aware, but I am no expert on French tax law. Logically, therefore, whichever stock exchange charges the most fees is likely to be the most "inefficient", to use your term.