Taxes Consolidation Act 1997 section 246

Interest payments by companies and to non-residents

Section 246 requires companies paying annual interest, and any person paying interest to a non-resident, to deduct income tax at the standard rate from those payments and account for the tax to Revenue, subject to a wide range of exceptions.

• A company paying annual interest to an Irish resident must deduct income tax at the standard rate, unless the payment falls within one of the listed exceptions.
• Any person paying interest to a non-resident must likewise deduct tax at the standard rate, ensuring Revenue can collect tax on Irish-source income paid abroad.
• Numerous exceptions apply, including interest paid to or by banks, interest between group companies, interest paid to investment undertakings, securitisation vehicles, NAMA, the NTMA, the Strategic Banking Corporation of Ireland, Home Building Finance Ireland, pension schemes, and interest paid to companies resident in treaty or EU countries.
• Finance and treasury companies that lend money in the ordinary course of trade may receive interest without deduction of tax, provided they have notified both Revenue and the paying company that they meet the qualifying conditions and have supplied their tax reference number.