Taxes Consolidation Act 1997 section 172C

Exemption from dividend withholding tax for certain persons

Section 172C provides that certain persons and entities, known as "excluded persons", may receive distributions from Irish resident companies without deduction of dividend withholding tax (DWT), provided they make the appropriate declaration of entitlement to exemption.

• Distributions made by an Irish resident company to an excluded person are exempt from DWT, meaning they are paid gross without the standard 25% withholding.
• The list of excluded persons includes Irish resident companies, pension schemes, qualifying fund managers, PRSA administrators, collective investment undertakings, charities, approved sports bodies, designated brokers, exempt unit trusts, permanently incapacitated individuals in receipt of certain compensation, and (from 1 January 2026) qualifying investment limited partnerships or equivalent partnerships.
• To qualify for the exemption, the excluded person must make the appropriate declaration, as set out in Schedule 2A, to the company paying the distribution, or to the qualifying intermediary or authorised withholding agent through whom the distribution is received.
• Certain entities — including collective investment undertakings, qualifying fund managers, PRSA administrators, PEPP providers, exempt unit trusts, investment limited partnerships, equivalent partnerships, and designated brokers — are treated as being beneficially entitled to the distributions they receive on behalf of others, so that they can make the necessary declarations and receive distributions gross.