Taxes Consolidation Act 1997 section 63

Exemption of dividends of non-residents

Section 63 provides an exemption from Irish tax on foreign dividends payable in the State for persons who are not resident in Ireland, and sets out the claims and appeals process.

• Non-residents are exempt from tax on foreign dividends payable in Ireland, but are not entitled to allowances or repayments in respect of that tax unless specifically provided for.
• Where foreign securities are held in trust and the sole beneficiary in possession can call for an absolute transfer of those securities, that beneficiary is treated as the owner for the purposes of the exemption.
• Relief under this section may be given by way of allowance or repayment on a claim made to the Revenue Commissioners.
• A person who disagrees with a Revenue decision on their residence status may appeal to the Appeal Commissioners within two months of the date of the notice of the decision.