267I Exemptions from tax and withholding tax

Summary

This section provides relief for interest and royalty payments made by a company in one Member State to its associated company in another Member State.

Details

Abolition of withholding tax in certain cases

(1) Interest and royalty payments made by a company in one Member State to its associated company in another Member State are to be free of withholding tax. Sections 238, 246(2) or 257, which generally impose an obligation to deduct tax from certain interest and royalty payments, are disapplied.

(2) Interest and royalty payments received by a company which is resident for tax purposes in a Member State other than the State are exempt from tax. The exemption does not apply where that interest and royalties is paid to the company in connection with a trade which is carried on in the State through a permanent establishment of that company.

Relevant Date: Finance Act 2021