Patent royalties

02/11/1993

Query

Can a company pay Patent Royalties without the deduction of Withholding Tax?

Decision

Yes, provided the Royalties are 'income from a qualifying Patent', as defined in S.234 TCA 1997, and the tax affairs of all parties are at all times up to date.

Corporation Tax

Section 234, Taxes Consolidation Act, 1997

Origin: Direct Taxes Interpretation & International

File ref:IR10407/1729/1993




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