Ireland Tax Agency Updates Guidance on Payment, Receipt of Interest, Royalties Without Deductions

The Irish Revenue Commissioners March 28 issued Revenue eBrief No. 103/24, updating guidance on the payment and receipt of interest and royalties without deduction of income tax. The guidance includes topics such as withholding tax, interest paid to U.S. companies, and the tax treatment of companies under the territorial system of Hong Kong. The updates include: 1) the implementation of defensive measures, through withholding taxes, on outbound payments of interest and royalties, as well as on distributions under certain circumstances, by Irish entities to associated entities that are based in specified territories; 2) additional guidance on applying interest withholding tax ...