Revenue Note for Guidance

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Revenue Note for Guidance

267J Credit for foreign tax

Summary

This section provides credit for foreign tax suffered on interest and royalty payments received by an Irish resident company from an associated company in Greece, Portugal or Spain in accordance with derogations given to those Member States under the Directive.

Details

(1) Credit is to be allowed for withholding tax suffered on interest and royalties received by an Irish resident company from an associated company in Greece, Portugal or Spain in accordance with derogations given to those Member States under the Directive.

(2) The mechanism in Schedule 24 applies for the purpose of giving such credit relief.

(3) This relief applies without prejudice to a provision of a bilateral agreement.

Relevant Date: Finance Act 2021