Taxes Consolidation Act 1997 Schedule 2, paragraph 23

Relief in respect of foreign-source interest, etc.

Paragraph 23 of Schedule 2 allows Revenue to relieve a paying agent in the State from the obligation to deduct income tax when distributing foreign-source interest, dividends or other annual payments on behalf of non-resident bodies.

• Applies where foreign public revenue or non-resident body payments are routed through a person in the State for onward payment to another person in the State
• Revenue may relieve the paying agent from the normal obligation to deduct income tax at source from those payments
• The obligation that may be relieved arises under section 17, Chapter 1 of Part 3, or Chapter 2 of Part 4
• The relief is discretionary — Revenue has the power to grant it but is not required to do so