Taxes Consolidation Act 1997 section 267I

Exemptions from tax and withholding tax

Section 267I provides relief from withholding tax and exemption from Irish tax for interest and royalty payments made between associated companies in different EU Member States.

• Sections 238, 246(2) and 257 (which normally require withholding tax on interest and royalty payments) do not apply to payments covered by this Chapter.
• A company resident for tax purposes in another EU Member State is not liable to Irish corporation tax or income tax on such interest or royalties.
• The exemption does not apply where the interest or royalties are connected with a trade carried on in Ireland through a permanent establishment of the receiving company.
• The relief applies only where the conditions set out elsewhere in this Chapter are satisfied.