Taxes Consolidation Act 1997 section 172A

Interpretation

Section 172A defines the key terms used in the dividend withholding tax (DWT) provisions and sets out how the amount of a relevant distribution is to be determined for DWT purposes.

• DWT at 25% must generally be deducted by an Irish-resident company from any distribution it makes, unless the recipient qualifies for an exemption and has completed the required declaration.
• A "relevant distribution" covers cash dividends, shares issued instead of cash, and other distributions of profits, but excludes distributions made to certain government bodies and those made by collective investment undertakings.
• Certain categories of recipient, including Irish-resident companies, pension schemes, qualifying non-resident persons, and qualifying intermediaries, may receive distributions without DWT being deducted.
• The amount of a relevant distribution for DWT purposes is always the gross amount before any deduction of DWT, whether the distribution is in cash, in shares, or in some other non-cash form.