Taxes Consolidation Act 1997 Schedule 2A paragraph 8

Declaration to be made by qualifying non-resident person, not being a company

Schedule 2A paragraph 8 sets out the requirements for the written declaration that a qualifying non-resident individual must make in order for an Irish resident company to pay a relevant distribution without deducting dividend withholding tax.

  • A qualifying non-resident person (not being a company) must make a written declaration to the paying company in a Revenue-prescribed form, signed by the person beneficially entitled to the distributions.
  • The declaration must confirm that the person is a qualifying non-resident person and must be accompanied by a certificate of tax residence from the relevant foreign tax authority.
  • Where distributions are received through a trust, the declaration must also be accompanied by a trustee certificate naming all settlors and beneficiaries, together with written confirmation from Revenue that they have noted the certificate.
  • The declarer must undertake to notify the paying company in writing if the person ceases to be a qualifying non-resident person, and must provide any other information Revenue may reasonably require.

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