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Revenue has updated the Tax and Duty Manual regarding the payment and receipt of interest and royalties without deduction of income tax. The updated manual reflects the introduction of the outbound payments defensive measures and provides additional guidance.
The updates are as follows:
in respect of the application of interest withholding tax to interest paid to Irish partnerships and foreign tax transparent entities (section 5.3), and
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 (section 9.1.1).
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