Under Schedule 2 Part 5 TCA 1997 the Revenue Commissioners may relieve a collecting agent from the obligation to retain income tax at the standard rate from the payment of foreign sourced interest, dividends or other annual payments to Irish residents. Revenue has announced that this relief will apply to collecting agents with effect from 1 January 2010 subject to the conditions outlined in eBrief No. 01/10.
The relief will apply to the payment of the foreign sourced interest or dividends made by a collecting agent to a "Qualifying Company" as defined in section 110 of TCA 1997
The conditions which must be satisfied are:
1. The collecting agent is satisfied that the payment is made to a "Qualifying Company" and
2. The collecting agent gives the details required on Statement No. 4 on the annual Foreign Dividends Return which is required under Schedule 2 Part 4 TCA 1997
From 1 January 2010, Revenue will issue acknowledgments of all notifications received from companies that they are/intend to be a "Qualifying Company". The acknowledgment must then be obtained by the collecting agent in order to satisfy condition 1. outlined above.
EBrief No. 01/10 is available here