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I noticed that a "Tax Relief Fee" is usually deducted from ADR dividends. Consider AXA ADR's (OTC: AXAHY) 2020 cash dividend announcement, which includes a "Tax Relief Fee" of $0.005 per share:

AXAHY 2020 Cash Dividend Announcement

Also consider Sony ADR's (NYSE: SNE) 2020 semi-annual dividend announcement:

SNE 2020 Cash Dividend Announcement

So here we have a clue:

Tax Relief at Source Processing Fee is for Tax Certification Filing

But what does this mean exactly? In particular, I would like to know:

  • Who charges this fee? Is it the ADR's depositary bank, or the Depository Trust Company (DTC)?
  • What is this fee used for? What is "Tax Certification Filing"?
  • Notice that in the case of the Sony ADR, the "Tax Relief Fee" decreases as the tax rate increases. Why?

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