Revenue has published a new Tax and Duty Manual to provide guidance on outbound payments defensive measures contained in Chapter 5 Part 33 TCA 1997, as introduced in Finance (No.2) Act 2023. The aim of these defensive measures is to prevent double non-taxation.
Chapter 5 Part 33 TCA 1997 provides for the implementation of defensive measures, by way of withholding taxes, on outbound payments of interest and royalties, and on the making of distributions, in certain circumstances. The measures apply to payments or distributions by Irish resident companies, or payments by Irish branches of non-resident companies, to associated entities who are resident, or situated, in specified territories.