Taxes Consolidation Act 1997 section 198

Certain interest not to be chargeable

Section 198 exempts certain interest payments and discounts from Irish income tax where the recipient is a non-resident who is tax resident in an EU Member State or a country with which Ireland has a double tax treaty.

• Interest paid by Shannon/IFSC companies or collective investment undertakings to non-resident companies or persons not ordinarily resident in the State is exempt from Irish income tax.
• Interest paid in the ordinary course of business by a company or collective investment undertaking to a non-resident company is exempt, provided the recipient is resident in an EU or treaty country that taxes foreign-source interest, or the interest is exempt under a double tax treaty.
• Interest on quoted Eurobonds, wholesale debt instruments, or asset-covered securities paid to a person resident in an EU or treaty country is exempt, including where the recipient is a non-resident company controlled by treaty-country residents or whose shares are publicly traded on a recognised stock exchange.
• Interest paid by a securitisation company (section 110 qualifying company) out of its assets to a non-resident person in an EU or treaty country, and discounts on securities issued in the ordinary course of business to such persons, are also exempt from income tax.