San Leon Energy Share Discussion Threads

[1kempton] 17/1/2021 21:19

hxxps://oilprice.com/Energy/Oil-Prices/Why-Oil-Will-Keep-Rising-In-2021.html

[1kempton] 17/1/2021 21:17

hxxps://thenationonlineng.net/nnpc-records-120-49m-crude-oil-receipt-in-september/

[1kempton] 08/1/2021 09:26

Gary it's on ii sle thread from linksdean all the written article is on there

[gary hindsight] 08/1/2021 08:13

Seems page has been removed now from that link

[1kempton] 07/1/2021 22:14

posted this back in oct 2020....

www.businesspost.ie/companies/exploration-company-san-leon-may-move-its-tax-base-to-britain

[echoridge] 07/1/2021 11:14

Now we're on the same page. On your question, I am learning and will revert

[gary hindsight] 07/1/2021 10:43

Thanks for the benefit of the doubt echoridge, I can assure you I am genuine, a shareholder and I fully understand scepticism of new posters. I gave up reading the SLE threads due to the vile posting by some so if you lived through that you have my sympathy.
I only looked in and commented because of this news announcement as for about 40 years I have been exposed to back office operations for banks and brokers globally and felt I could contribute to the discussion. If I offended anyone I apologise, that is not my way.
As you know, the company's country of incorporation is Ireland and when a dividend is paid the company or its appointed paying agent may not know the tax residency of the underlying beneficial owners. It will know it is paying it to a UK nominee (Barclays, HL etc) but it will be paid with standard, non documented, tax rate deducted for non-residents which for Ireland is 25%. I have seen some custodians organise their nominee accounts into tax buckets in which case they can certify that all underlying beneficial holders are UK residents or all beneficial owners can avail of 15% Double taxation agreement rates in which case only 15% is deducted at source by the paying agent, meaning the tax reclaim element is already accounted for. For those custodians that don’t bother they just pass on the 25% deduction and make each individual make a subsequent reclaim.
If the company was to change its country of incorporation to the UK the paying agent would be paying them as gross to a UK nominee and it would be up to the custodian to deduct tax for their underlying holders if they are not UK.
Whilst I accept the company has said it is considering its domicile issue I didn’t think it had made a commitment to do so and it says as much in the quoted piece from TW that it was a rumour and explicitly refers to re-domicile from Eire to UK which is what I am saying needs to be done. As I mentioned in my original post, to change its domicile to UK would increase its Corporation tax liability and that may have bearing but it is this country of incorporation / domicile which drives the tax deduction.

Just re-reading your post 51226 where you say that keeping the company Irish but registering in UK for tax purpose, how do you see that being done? Corporate structures is not my area of expertise

[echoridge] 07/1/2021 07:52

Not my usual m.o. but here goes my first effort at peacemaker: Alaric - I get it, but for what it's worth, I reckon Gary is legit. Gary - you continue to labour under a couple of misconceptions (e.g., the tax domicile change the company is pursuing would be a solution to the franking problem, allowing either brokers to pay any divi gross or - more likely - making it simpler for shareholders to reclaim any tax withheld, I'm not clear yet which. That's it. In addition fwiw, a divi is a divi. If you own your shares with a spread bet firm, the divi paid is every bit as real as for any other shareholder and not 'manufactured', though I admit that's a far less important point). Most important though, the reason that someone like Alaric might - and I want to be careful not to speak for him - be inclined to distrust a new poster who seems to be promoting an untruth against the company (i.e., that the tax withholding problems some shareholders suffered will necessarily continue even though it was explained publicly that a solution is being pursued), is because this board and the company more generally has suffered more than most from an organised trolling campaign of misinformation and lies for many years which appear finally to have been overcome. Hopefully, this helps.

[gary hindsight] 06/1/2021 22:45

What is it with bulletin boards that makes people so aggressive for no reason? It's beyond meNothing I wrote was twaddle it is 100% factually correct. I never meant to upset echoridge in the first place. He then gracefully apologised for saying I was talking twaddle and I accepted his apology. That's the end of it then you decide to pitch in and say it again. I would be interested If you can explain politely what piece of my post was untrue

[gary hindsight] 06/1/2021 17:44

Similarly last post on this from meApology accepted no issuetax on any dividend will be taxed until the company changes its tax domicile that's different or confusing to me but no need to respond given your last post was your last on it. Was only talking about actual dividends and not manufactured divs on spreadbetsEnough said from me

[echoridge] 06/1/2021 17:03

Ok, so last post on this. 1. 'twaddle' was harsh. Sorry; 2. you are not agreeing with me, but I hope you see that now. There is today's RNS re moving settlement systems for the shares and it has nothing whatever to do with fixing our tax jurisdiction which the company has previously announced they are working on. What you posted was confusing at best. 3. no one posted that they were expecting divs either net or gross of tax, only that they expected another special divi this year. There is no imminent divi announced so the likelihood is that the company will effect a solution to avoid withholding BEFORE the next special divi is confirmed (btw, as I have noted before, not all shareholders were disadvantaged. For instance, anyone owning the shares on spread bet or with an institution that has an Irish office, were paid gross or were able to reclaim the franked amount relatively quickly)

[gary hindsight] 06/1/2021 16:27

So firstly I only posted as subsequent to your post there were other posters that seemed to be saying that they were now expecting gross divs. Or at least that's how I interpreted there comment and I was merely pointing out and agreeing with you that this does not solve the wht tax issue at allYes I am aware of the tw point where they said they are looking at it but until they change their domicile these will be taxed. I am floored as to your point that I am speaking twaddle as I am actually agreeing with you thus if I am talking twaddle so are you.

[echoridge] 06/1/2021 15:36

'....So get ready for Irish withholding tax on the divs....' This is objectively false. I will give you the benefit of the doubt that this is innocent twaddle and not meant to purposefully misinform.

[gary hindsight] 06/1/2021 12:48

I don't think this change helps or changes the tax situation at all. Due to brexit Irish companies cannot settle in crest so they are moving them to another csd. Euroclear. This makes them even more clearly a non uk company with Irish tax applicable. They say there is no alternative but there was. Become a uk listed company and stay in crest but they have chosen not to. Corporation tax is lower in Ireland than uk I think and probably why they are staying Irish So get ready for Irish withholding tax on the divs

[1kempton] 06/1/2021 09:04

I have already as all things lining up this year with revenues from fso, loan notes and hopefully eroton dividend, could mean a bumper dividend with OF words returning 60% back to shareholders.

[plasybryn] 06/1/2021 08:53

Brilliant- I was almost of a mind to sell. If true I could see myself definitely adding here.

[echoridge] 06/1/2021 08:49

Thank you, Philby. I knew that I had read the Company's strategy on this somewhere.

[plasybryn] 06/1/2021 08:34

Great news if that is correct echoridge, but why not spell that out in the RNS if true, as it is something that has really annoyed shareholders

[echoridge] 06/1/2021 08:04

Well, potentially, keeping the Company 'Irish' but registering it in the UK for tax purposes. That should solve the issue in my view, and as I said, today's technical settlement issue, created by Brexit, is completely independent of that. Watch this space

[1kempton] 06/1/2021 08:01

Looks to me dividend will be made in full

[plasybryn] 06/1/2021 07:48

Continuing effort to resolve tax issue. What effort is that?

[echoridge] 06/1/2021 07:46

You support it because its an entirely technical matter made necessary by Brexit, will result in absolutely no inconvenience for the punter AND in no way precludes management's continued effort to solve the tax issue. [In addition of course, any vote is itself just a technicality since the 80%+ held by Tosca, management, etc will pass the resolutions]