Dividend imputation taxes and the curious case of a price premium between BHP and Billiton American depositary receipts

Abstract

AbstractBHP Group was formed in 2001 when the Broken Hill Proprietary Company Limited in Australia merged with the Anglo–Dutch Billiton Plc in the UK to form a dual−listed company. The American Depositary Receipts (ADRs) for BHP and Billiton trade on the NYSE, and despite these two securities having exactly the same voting rights and US dollar denominated dividends, the BHP ADR generally sells at a premium to the Billiton ADR, though that premium has considerable time−series variation. We investigate whether differences in the imputation tax systems that apply to dividends in Australia and the UK help explain the time series variation in the premium of the ADR prices. Our results confirm that imputation tax differences are a significant determinant of the premium. Our paper hence provides direct evidence that imputation tax credits are capitalised into equity prices.