Taxes Consolidation Act 1997 section 64

Interest on quoted Eurobonds

Section 64 sets out the circumstances in which interest on quoted Eurobonds may be paid without deduction of withholding tax, and the obligations on paying and receiving agents regarding declarations of non-residence and record-keeping.

• Interest on quoted Eurobonds can be paid gross where the payer is outside the State, the bonds are held in a recognised clearing system, or the beneficial owner is non-resident and has made a declaration of non-residence.
• Agents paying Eurobond interest in the State must report gross payments to Revenue within 12 months, identifying themselves and describing the payment, and must retain non-residence declarations for at least six years or three years after the last interest payment.
• Where a receiving agent in the State obtains Eurobond interest on behalf of another person, encashment tax must be deducted unless the beneficial owner is non-resident and has completed a declaration of non-residence.
• Non-residence declarations must include the beneficial owner's name, principal residential address, and country of residence, together with an undertaking to notify the payer if the beneficial owner becomes resident in Ireland.