Taxes Consolidation Act 1997 section 61

Dividends entrusted for payment in the State

Section 61 deals with the taxation of foreign dividends that are entrusted to a person in the State for payment to other persons in the State.

• Where foreign dividends are entrusted to an Irish-based paying agent for distribution to recipients in the State, those dividends are assessable to tax.
• The assessment and charge to tax is made under Schedule D by the Revenue Commissioners.
• The collection and enforcement rules set out in Parts 1, 4 and 5 of Schedule 2 apply to the tax charged under this section.
• The effect is that the Irish paying agent, rather than the individual recipients, bears the primary responsibility for the tax assessment on these foreign dividends.