Withholding tax Self-Certification

Mar 15, 2021

The Tax and Duty Manual Part 08-03-06 - Payment and Receipt of Interest without Deduction of Income Tax – is updated to provide for the introduction of a Self-Certification system for circumstances where taxpayers can withhold tax at the double tax agreement (DTA) rate from interest or royalties paid to residents of a treaty partner, rather than withhold and remit an amount of tax that is subsequently refundable under the DTA. The manual now also confirms that the Central Bank of Ireland is a bank carrying on a bona fide banking business for the purpose of section 246 TCA 1997.

Guidance on the meaning of the term “paid in the State” for the purpose of exemptions contained in section 246(3) TCA 1997 is also included in the TDM. The term “paid in the State” means the payment of any yearly interest amounts where –

(a) the source of interest payments is in the State, and
(b)the payment of the interest is, without regard to the exemption contained in section 246(3), within the scope of Irish interest withholding tax under section 246(2).

See eBrief No. 054/21 for further details.