eBrief No. 114/17

12 December 2017

Revised tax treatment of interest and royalties: Ireland-Chile Double Taxation Convention

Ireland’s Double Taxation Convention (DTC) with Chile came into effect on 1 January 2009. It contains a provision whereby the tax treatment of interest income and of royalty income under the Convention are revised in the event of more favourable terms being agreed subsequent to 1 January 2009 by Chile with another OECD country. Chile has agreed such terms with Japan and those terms are now to apply to the Ireland-Chile DTC with effect from 1 January 2017.

The net result of the revisions is that the withholding tax rate on interest payments is reduced from 15% or 5% to 4% in certain circumstances and the withholding tax on royalty payments for the use of, or the right to use, any industrial, commercial or scientific equipment is reduced from 5% to 2%. The changes became effective from 1 January 2017.

See Tax and Duty Manual Part 35-01-09.