Revenue eBrief No. 103/24
28 March 2024
Payment and receipt of interest and royalties without deduction of income tax
Tax and Duty Manual 08-03-06 ‘Payment and receipt of interest and royalties without deduction of income tax’ has been updated:
- to reflect the introduction of the outbound payments defensive measures contained in Chapter 5 of Part 33 of the Taxes Consolidation Act 1997, refer to section 1.3,
- to provide additional guidance in respect of the application of interest withholding tax to interest paid to Irish partnerships and foreign tax transparent entities, refer to section 5.3, and
- to provide additional guidance on payments of interest to tax transparent entities where members of those entities may avail of the rate of withholding tax provided for under the terms of a double taxation agreement, refer to section 9.1.1.