Dividend Withholding Tax Information

Medtronic plc has established tax residence in Ireland, and as such, dividends are considered Irish source income and Irish dividend withholding tax (“DWT") rules apply. Beginning with the dividend payable on April 15, 2015, payments will be subject to an Irish withholding tax unless the shareholder that is beneficially entitled to the dividend is a resident of the United States or a resident of a country listed as a “relevant territory”, and has ensured that the required information is on file with their broker, bank, qualifying intermediary or transfer agent (see below for more detail). With these rules, the vast majority of Medtronic shareholders and beneficial owners are entitled to an exemption from DWT.

Please answer the following questions to find out how to obtain an exemption from the Irish Dividend Withholding Tax (DWT) on your Medtronic plc shares. A W-9 or a W8-BEN is still required to avoid United States Dividend Tax withholding. You may already have these documents on file with your financial institution.

If Irish Dividend Withholding Tax (DWT) has been previously assessed to your account and you are looking for direction on claiming a tax refund or tax credit information click here.

It is up to each individual to review each alternative as it applies to their specific situation, evaluate its viability in the context of your overall investment strategy, and decide which one is right for you. As part of this process, you may wish to consult your own broker, financial advisor or tax advisor for their professional assistance. Not all alternatives may be right for you. Not all alternatives may apply to you.

Q1: Are your Medtronic plc shares held by EQ Shareowner Services?

Yes / No

Q2: Are your Medtronic plc shares held by a broker and are you a tax resident of the United States?

Yes / No

Q3: Are you a tax resident of the United States?

Yes / No

Q4: Are you a resident of a relevant territory other than the U.S. (as defined by Irish Law)? To determine which countries are considered a relevant territory, please visit this link.

Yes / No

Q5: Was your EQ Shareowner Services (WFSS) account established by the transfer and conversion of your Covidien plc shares from Computershare account to Medtronic plc shares?

Yes / No

Q6: Are you a Corporate Entity?

Please see the GlobeTax FAQ for additional information.

Q7: Are you a resident of one country but a taxpayer in another?

Please see the GlobeTax FAQ for additional information.

.

WFSS > Tax Resident of the US

Options to Obtain Irish DWT Exemption	Description	Required Forms
1. Transfer Your Shares to a Broker	Transfer your shares from EQ Shareowner Services (WFSS) to a broker. Ensure that your broker has your Form W-9 on file. Confirm with your broker that they can certify that you have a valid US address with a Form W-9. If your broker has questions on applying for the exemption, they can visit www.dtcc.com and search “Medtronic” for instructions.	US Tax Residents need a valid W-9
2. Continue to hold in Direct Registry at EQ Shareowner Services (WFSS)	In order to obtain an Irish DWT exemption, you will need to register with and pay a $149.99 (USD) service fee to GlobeTax, which will maintain your exemption through the end of the fifth year following the signing with no need to provide any additional documentation. $85.00 of the $159.99 service fee is paid to the IRS to obtain the US Certificate of Residency. $64.99 is retained by GlobeTax for administration of the service. To ensure your Irish DWT exemption, initiate your GlobeTax registration as soon as possible, at least 45 business days prior to the dividend record date. If you do not act, statutory dividend withholding tax will continue to be applied to your dividend payments. Irish DWT is withheld at a rate of 20% on dividends paid between April 15, 2015 and December 31, 2019. From January 1, 2020 Irish DWT is withheld at a rate of 25%. Please consult with your tax advisor for further options.	GlobeTax Registration: Complete the “New Users Register Here” section Use the access code “MedtronicRSH” Follow the instructions provided
3. File forms with GlobeTax each quarter	If you want to continue to hold your shares with WFSS and you have not selected option 1 or 2 to obtain an exemption, then each quarter, the only remaining option is to file a US Certificate of Residency (IRS Form 6166) and the Irish Form V2 along with a cover letter each quarter with GlobeTax to maintain your exemption. There is no charge from GlobeTax to file each quarter. You must pay an $85 fee to the IRS and file the IRS Form 8802, which is the application required by the IRS to issue the US Certificate of Residency (Form 6166). The 6166 and V2 need to be lodged with GlobeTax prior to each dividend record date.	US IRS-8802 to obtain the US Certification of Residency, IRS Form 6166; File 6166 with V2 with GlobeTax each quarter. Each quarterly submission must include a new cover letter with Name, Telephone Number and Email Address, the Security Name (Medtronic plc), Record Date, Account Name and EQ Shareowner Services Account number. The quarterly submission will need to be sent to GlobeTax every quarter using tracked mail (e.g. FedEx, UPS, DHL, Certified USPS Mail or similar). Globe Tax locations A W-9 will need to be on file with WFSS
4. Sell your shares	Medtronic values all shareholders and hopes you remain a shareholder. However, we understand that, after reviewing each alternative and evaluating its viability in the context of your overall investment strategy, you might decide this alternative is right for you. If you sell your MDT shares, and don’t purchase new MDT shares, you will not receive dividends - and will not be required to pay Irish DWT. Note – For shares purchased under Medtronic’s Employees Stock Purchase Plan (ESPP), this option is only available if you purchased your shares more than 12 months ago. You should consult your tax advisor regarding the tax consequences of selling your shares.
	If you take no action, Irish DWT will be withheld from your Medtronic plc dividend payments. The dividend payment you receive will be reduced by the Irish DWT. Irish DWT is withheld at a rate of 20% on dividends paid between April 15, 2015 and December 31, 2019. From January 1, 2020 Irish DWT is withheld at a rate of 25%.

WFSS >Tax Resident of the US > Legacy COV Direct Holder

Legacy Covidien plc shareholders whose shares were converted to Medtronic plc shares and transferred from Computershare to EQ Shareowner Services (WFSS) may have the Irish Form V2 on file with GlobeTax. This V2 is valid through the expiration date. The V2 Exemption Declaration Form is valid from the certificate’s date of issue to the 31st day of December five years following the year in which the certificate was issued (i.e. the form is valid for the year in which it is signed plus five full calendar years).

If you do not have a valid W-9, W8-BEN (as appropriate) and the Form V2 in place or missed a deadline for filing and were subject to the withholding, click here for more details on reclaiming those funds.

Once completed, forward the Form V2 to GlobeTax, your Broker or other Qualifying Intermediary to ensure exemption. Please do not send the Form V2 to the Ireland DWT Unit or Medtronic for the purpose of gaining ‘exemption-at-source’.

WFSS > Tax Resident Outside the United States (OUS) in a Relevant Territory (as defined by Irish Law)

Options to Obtain Irish DWT Exemption	Description	Required Forms
1. Transfer Your Shares to a Broker	Transfer your shares from EQ Shareowner Services (WFSS) to a broker. Ensure that your broker has your stamped Form V2 and a valid US address on file. Confirm with your broker that they will file the Irish DWT exemption. If your broker has questions on applying for the exemption, they can visit www.dtcc.com and search “Medtronic” for instructions. Generally, for US Tax Residents the DTC Participants are automatically considered a Specified Intermediary and can claim the exemption based on the investors US address. For Non-US Tax Residents the DTC Participants send the Form V2 to EQ Shareowner Services/GlobeTax as the Qualified Intermediary and they can claim the DWT exemption.	OUS Tax Residents need a valid W8-BEN Select the appropriate Form V2 here
2. Continue to hold in Direct Registry at EQ Shareowner Services (WFSS)	In order to obtain an Irish DWT exemption, you will need to register with and pay a $50 (USD) service fee to GlobeTax, which will maintain your exemption through the end of the fifth year following the signing.	GlobeTax Registration: Complete the “New Users Register Here” section Use the access code “MedtronicRSH” Follow the instructions provided
3. File forms with GlobeTax each quarter	You need to file a stamped Form V2 along with a cover letter each quarter with GlobeTax before the record date to obtain the Irish DWT exemption. There is no charge from GlobeTax to file each quarter.	Ireland Department of Revenue DWT Forms Each quarterly submission will need to include, a new cover letter with Name, Telephone Number and Email Address, the Security Name (Medtronic plc), Record Date, Account Name and EQ Shareowner Services Account number. It will need to be sent to GlobeTax every quarter using tracked mail (e.g. FedEx, UPS, DHL, Certified USPS Mail or similar). Globe Tax locations
4. Sell your shares	Medtronic values all shareholders and hopes you remain a shareholder. However, we understand that, after reviewing each alternative and evaluating its viability in the context of your overall investment strategy, you might decide this alternative is right for you. If you sell your MDT shares, and don’t purchase new MDT shares, you will not receive dividends - and will not be required to pay Irish DWT. Note – For shares purchased under Medtronic’s Employees Stock Purchase Plan (ESPP), this option is only available if you purchased your shares more than 12 months ago. You should consult your tax advisor regarding the tax consequences of selling your shares.
	If you take no action, Irish DWT will be withheld from your Medtronic plc dividend payments. The dividend payment you receive will be reduced by the Irish DWT. Irish DWT is withheld at a rate of 20% on dividends paid between April 15, 2015 and December 31, 2019. From January 1, 2020 Irish DWT is withheld at a rate of 25%.

Legacy Covidien Holders > WFSS > Tax Resident Outside the United States (OUS) in a Relevant Territory as defined by Irish Law > Account Established or Changed after 1/26/15

Legacy Covidien plc shareholders whose shares were converted to Medtronic plc shares and transferred from Computershare to EQ Shareowner Services (WFSS) may have a valid W8-BEN and the Irish Form V2 in place with GlobeTax. This V2 is valid through its expiration date. V2 forms should be renewed 45-60 days prior to expiration. The V2 Exemption Declaration Form is valid from the certificate’s date of issue to the 31st day of December five years following the year in which the certificate was issued. (i.e. the form is valid for the year in which it is signed plus five full calendar years after that. If the holder did not have a valid W8-BEN or V2 (as appropriate) in place or missed a deadline for filing and was subject to the withholding, you can click here for more detail on reclaiming those funds.

Once completed, forward your forms to GlobeTax, your Broker or other Qualifying Intermediary so that exemption can be put in place. Please do not send the forms to the Ireland DWT Unit or the Company for the purpose of gaining ‘exemption-at-source’.

WFSS > Tax Resident Outside the United States (OUS) whom > Does not reside in a Relevant Territory (as defined in Irish Law)

It is likely that you are not exempt from paying the Irish DWT. Check with your tax advisor to see if there are any options that apply to your special situation.

Option	Description
The only remaining option to avoid DWT may be to sell your shares	Medtronic values all shareholders and hopes you remain a shareholder. However, we understand that, after reviewing each alternative and evaluating its viability in the context of your overall investment strategy, you might decide this alternative is right for you. If you sell your MDT shares, and don’t purchase new MDT shares, you will not receive dividends - and will not be required to pay Irish DWT. Note – For shares purchased under Medtronic’s Employees Stock Purchase Plan (ESPP), this option is only available if you purchased your shares more than 12 months ago. You should consult your tax advisor regarding the tax consequences of selling your shares.

Option

Description

The only remaining option to avoid DWT may be to sell your shares

Medtronic values all shareholders and hopes you remain a shareholder. However, we understand that, after reviewing each alternative and evaluating its viability in the context of your overall investment strategy, you might decide this alternative is right for you.

If you sell your MDT shares, and don’t purchase new MDT shares, you will not receive dividends - and will not be required to pay Irish DWT.

Note – For shares purchased under Medtronic’s Employees Stock Purchase Plan (ESPP), this option is only available if you purchased your shares more than 12 months ago.

You should consult your tax advisor regarding the tax consequences of selling your shares.

Tax Resident of US with Shares Held by Broker (US)

You should be exempt from paying the Irish DWT, assuming:

You have a Form W-9 and a valid United States address on file with your broker; and
You’ve confirmed with your broker that they can certify a valid US address with a Form W-9.

If your broker has questions on applying for the Irish DWT exemption, they can visit http://www.dtcc.com and search “Medtronic” for instructions. These instructions also include details on the treatment of special situations, such as trusts or partnerships. Generally, for US Tax Residents, the DTC Participants are automatically considered a Specified Intermediary and can claim the exemption based on the investor’s US address. For Non-US Tax Residents, their U.S. banks or brokers (aka DTC Participants), who are not Qualifying Intermediaries, send the Form V2 to EQ Shareowner Services/GlobeTax as the Qualified Intermediary and they can claim the DWT exemption.

Resident of a Relevant Territory Outside the U.S. with Shares Held by Broker (OUS)

To receive an Irish DWT exemption:

Ensure that your broker has your Form V2 on file, which is available here
Confirm with your broker that they will file the Irish DWT exemption

If your broker has questions on applying for the exemption, they can visit www.dtcc.com and search “Medtronic” for instructions. These instructions include country-by-country filing requirements as well as instructions on treatment of special situations, such as trusts or partnerships. For Non-US Tax Residents, their U.S. banks or brokers (aka DTC Participants), who are not Qualifying Intermediaries, send the Form V2 to EQ Shareowner Services/GlobeTax as the Qualified Intermediary and they can claim the DWT exemption in that manner.

This page is intended to give helpful direction to holders who have had Irish Dividend Withholding Tax (DWT) applied to their account and are looking for information on claiming a tax refund or tax credits.

Investors should not view this detail as a substitute for a knowledgeable tax advisor and we advise that you seek their guidance in these often complex tax situations.

Question	Description	Forms
I am a United States Tax Resident. How do I claim a refund of Irish DWT from the Irish Tax Authority	If you do not obtain an exemption from Irish DWT, you may apply for a refund directly from the Irish Tax Authority. Refund claims may be made in the same year as the Irish DWT was withheld, however they must be made within four years from the end of the calendar year in which the tax was deducted (e.g. a refund claim for Irish DWT withheld in April 2016 must be made by 31 December 2020). Total cost over five years includes a $85 (USD) IRS “user fee,” plus postage/courier fees Refunds are issued by the Irish Revenue Commissioners in € Euros by check. It is common for refunds filed directly to the Irish Revenue Commissioners to take 9-12 months to pay. GlobeTax may be able to assist you for a fee of $0.0075 (USD) per share with a minimum fee of $25 (in addition to the $85 paid to the IRS), but you do not need to use GlobeTax to claim a refund of Irish DWT. If you wish to use GlobeTax, contact them at eCertsMedtronicRSH@globetax.com, or +1 855 849 3119. Refunds paid through GlobeTax will be made in $ USD by check. Refunds through GlobeTax are often received in half the time as filing directly.	File Form 8802 with the IRS, paying the $85 (USD) “user fee,” to obtain IRS Form 6166. Submit to Irish Revenue the following forms using tracked mail (e.g. FedEx, UPS, DHL, certified mail via USPS, or similar): Completed refund claim form Original dividend vouchers Form 6166* Form V2* All other forms required by Irish Revenue:refer to the “Dividend Withholding Tax Refund Claim Form – Claim from or on behalf of Certain Non-Resident Persons for Refund of DWT”. * You do not need to complete these new forms with each refund claim:these forms are valid for the year in which they are signed, plus five full calendar years following. You will still need to submit one of these forms to EQ Shareowner Services: If you are a U.S. resident:Form W-9 If you are not a U.S. resident:Form W-8BEN
I am tax filer residing outside the United States. How do I claim a refund of Irish DWT from the Irish Tax Authority	If you do not obtain an exemption from Irish DWT, you may apply for a refund directly from the Irish Tax Authority. Refund claims may be made in the same year as the Irish DWT was withheld, however they must be made within four years from the end of the calendar year in which the tax was deducted (e.g. a refund claim for Irish DWT withheld in April 2016 must be made by 31 December 2020). Total costs over five years are postage/courier fees. Refunds are issued by the Irish Revenue Commissioners in € Euros by check. GlobeTax may be able to assist you for a fee of $0.0075 (USD) per share with a minimum fee of $25, but you do not need to use GlobeTax to claim a refund of Irish DWT. If you wish to use GlobeTax, contact them at eCertsMedtronicRSH@globetax.com, or +1 855 849 3119. Refunds paid through GlobeTax will be made in $ USD by check. Refunds through GlobeTax are often received in half the time as filing directly.	Submit to Irish Revenue the following forms using tracked mail (e.g. FedEx, UPS, DHL, certified mail via USPS, or similar): Completed refund claim form Original dividend vouchers Form V2* All other forms required by Irish Revenue:refer to the “Dividend Withholding Tax Refund Claim Form – Claim from or on behalf of Certain Non-Resident Persons for Refund of DWT” here. *You do not need to complete this new form with each refund claim:this form should be valid for the year in which it is signed, plus five full calendar years following You will still need to submit one of these forms to EQ Shareowner Services: If you are a U.S. resident:Form W-9 If you are not a U.S. resident:Form W-8BEN
Claim a foreign tax credit on your income tax return for the Irish DWT you paid.	It can be difficult to satisfy the requirements for a tax credit. You should consult your tax advisor to see if this is possible.	You should consult your individual tax advisor to see what additional forms you may need to file with your income tax return, if any. You will still need to submit one of these forms to EQ Shareowner Services: If you are a U.S. resident:Form W-9 If you are not a U.S. resident:Form W-8BEN

Question

Description

Forms

I am a United States Tax Resident. How do I claim a refund of Irish DWT from the Irish Tax Authority

If you do not obtain an exemption from Irish DWT, you may apply for a refund directly from the Irish Tax Authority.
Refund claims may be made in the same year as the Irish DWT was withheld, however they must be made within four years from the end of the calendar year in which the tax was deducted (e.g. a refund claim for Irish DWT withheld in April 2016 must be made by 31 December 2020).
Total cost over five years includes a $85 (USD) IRS “user fee,” plus postage/courier fees
Refunds are issued by the Irish Revenue Commissioners in € Euros by check.
It is common for refunds filed directly to the Irish Revenue Commissioners to take 9-12 months to pay.
GlobeTax may be able to assist you for a fee of $0.0075 (USD) per share with a minimum fee of $25 (in addition to the $85 paid to the IRS), but you do not need to use GlobeTax to claim a refund of Irish DWT.
If you wish to use GlobeTax, contact them at eCertsMedtronicRSH@globetax.com, or +1 855 849 3119.
Refunds paid through GlobeTax will be made in $ USD by check.
Refunds through GlobeTax are often received in half the time as filing directly.

File Form 8802 with the IRS, paying the $85 (USD) “user fee,” to obtain IRS Form 6166.
Submit to Irish Revenue the following forms using tracked mail (e.g. FedEx, UPS, DHL, certified mail via USPS, or similar):
- Completed refund claim form
- Original dividend vouchers
- Form 6166*
- Form V2*
- All other forms required by Irish Revenue:refer to the “Dividend Withholding Tax Refund Claim Form – Claim from or on behalf of Certain Non-Resident Persons for Refund of DWT”.

* You do not need to complete these new forms with each refund claim:these forms are valid for the year in which they are signed, plus five full calendar years following.

You will still need to submit one of these forms to EQ Shareowner Services:

If you are a U.S. resident:Form W-9
If you are not a U.S. resident:Form W-8BEN

I am tax filer residing outside the United States. How do I claim a refund of Irish DWT from the Irish Tax Authority

If you do not obtain an exemption from Irish DWT, you may apply for a refund directly from the Irish Tax Authority.
Refund claims may be made in the same year as the Irish DWT was withheld, however they must be made within four years from the end of the calendar year in which the tax was deducted (e.g. a refund claim for Irish DWT withheld in April 2016 must be made by 31 December 2020).
Total costs over five years are postage/courier fees.
Refunds are issued by the Irish Revenue Commissioners in € Euros by check.
GlobeTax may be able to assist you for a fee of $0.0075 (USD) per share with a minimum fee of $25, but you do not need to use GlobeTax to claim a refund of Irish DWT.
If you wish to use GlobeTax, contact them at eCertsMedtronicRSH@globetax.com, or +1 855 849 3119.
Refunds paid through GlobeTax will be made in $ USD by check.
Refunds through GlobeTax are often received in half the time as filing directly.

Submit to Irish Revenue the following forms using tracked mail (e.g. FedEx, UPS, DHL, certified mail via USPS, or similar):
- Completed refund claim form
- Original dividend vouchers
- Form V2*
- All other forms required by Irish Revenue:refer to the “Dividend Withholding Tax Refund Claim Form – Claim from or on behalf of Certain Non-Resident Persons for Refund of DWT” here.

*You do not need to complete this new form with each refund claim:this form should be valid for the year in which it is signed, plus five full calendar years following

You will still need to submit one of these forms to EQ Shareowner Services:

If you are a U.S. resident:Form W-9
If you are not a U.S. resident:Form W-8BEN

Claim a foreign tax credit on your income tax return for the Irish DWT you paid.

It can be difficult to satisfy the requirements for a tax credit. You should consult your tax advisor to see if this is possible.

You should consult your individual tax advisor to see what additional forms you may need to file with your income tax return, if any.

You will still need to submit one of these forms to EQ Shareowner Services:

If you are a U.S. resident:Form W-9
If you are not a U.S. resident:Form W-8BEN

HELPFUL WEB RESOURCES

Web Resource	Link
US Depository Trust Clearing Company (DTC)	http://dtcc.com/
DTC Tax Relief by Country FAQs	https://www.dtcc.com/settlement-and-asset-services/global-tax-services/tax-relief-by-country Ireland:Link
US IRS Form W-9	https://www.irs.gov/pub/irs-pdf/fw9.pdf
US IRS Form W8-BEN	https://www.irs.gov/pub/irs-pdf/fw8ben.pdf
US IRS Form 8802	https://www.irs.gov/pub/irs-pdf/f8802.pdf
US IRS International Tax Payers	https://www.irs.gov/Individuals/International-Taxpayers
US IRS International Tax Payer Identification Numbers	https://www.irs.gov/Individuals/International-Taxpayers/Taxpayer-Identification-Numbers-TIN
Ireland DWT Overview	https://www.revenue.ie/en/companies-and-charities/dividend-withholding-tax/index.aspx
Ireland DWT Exemption Forms	https://www.revenue.ie/en/companies-and-charities/dividend-withholding-tax/exemptions-for-non-residents.aspx
Ireland Tax Treaties – List of Relevant Countries	http://www.revenue.ie/en/practitioner/law/tax-treaties.html
Ireland Verified List of Authorized Qualifying Intermediaries & Withholding Agents	https://www.revenue.ie/en/companies-and-charities/dividend-withholding-tax/what-are-a-qualifying-intermediary-and-authorised-withholding-agent.aspx
Ireland DWT Refund Tax Forms	https://www.revenue.ie/en/companies-and-charities/documents/dwt/dwt-claim-for-refund.pdf
Ireland Taxes & Duties	http://www.revenue.ie/en/tax/index.html
GlobeTax	https://ecerts.globetax.com/
Globe Tax Contact Information	Also in the Globe Tax Contact Information can you remove the link which doesn’t work and add: Ph Icon: +1-212-747-9100 Email Icon: info@globetax.com
GlobeTax Forms	https://ecerts.globetax.com/
EQ Shareowner Services	https://www.shareowneronline.com/UserManagement/WFIndex.aspx

Note: The information contained within this tool is meant to be helpful guidance and is not intended as tax advice. Investors should consult their tax advisor to understand options to address dividend withholding tax issues under Irish law.