Taxes Consolidation Act 1997 Schedule 2 paragraph 28

Certain foreign-sourced payments

Paragraph 28 of Schedule 2 removes the obligation to deduct income tax at source from certain foreign-sourced payments where those payments are made to an investment undertaking taxed under the gross roll-up regime.

• Applies to interest, dividends or other annual payments from foreign public revenue or from stocks, funds, shares or securities of non-resident bodies
• Where such payments are entrusted to a person in the State for onward payment to a qualifying investment undertaking, the normal withholding obligation is disapplied
• The investment undertaking must fall within the definition in section 739B, meaning it is subject to the exit tax (gross roll-up) regime rather than annual taxation
• This paragraph overrides paragraph 23 of Schedule 2, which would otherwise require the person entrusted with the payment to account for income tax on it