Taxes Consolidation Act 1997 Schedule 24 paragraph 9G

Dividends paid by companies that are taxed as a group under the law of a territory outside the State

Paragraph 9G sets out the mechanism for granting double taxation relief where a dividend is received from, or paid to, a foreign company that belongs to a group taxed on a consolidated basis under the law of a territory outside the State.

• Where foreign law treats a group of companies as a single taxable entity, dividends paid or received by any group member are treated for Irish double taxation relief purposes as paid or received by a notional "single company" representing the entire group.
• The single company is deemed resident in the territory where the responsible company (the company that accounts for the consolidated tax) is resident, and has a single aggregate figure for relevant profits and foreign tax.
• Relationship and connection tests (such as whether companies are related or connected) are preserved by reference to the actual group company involved in the dividend transaction.
• Additional deeming rules ensure that the existing Schedule 24 machinery — including the relevant dividend, connected company, and body corporate concepts — operates correctly in relation to the notional single company.