Taxes Consolidation Act 1997 section 830

Relief to certain companies liable to foreign tax

Section 830 provides relief from double taxation on dividends and interest received from subsidiaries in countries with which Ireland does not have a tax treaty, where the investment was funded from export sales-relieved or Shannon exempt profits.

• Where a company has invested export sales-relieved or Shannon exempt profits in a 51% subsidiary in a non-treaty country, and pays external tax on dividends or interest from that subsidiary, it may claim a credit for the lesser of 50% of the corporation tax otherwise payable on that income and the external tax paid.
• External tax means tax corresponding to Irish income tax or corporation tax payable in the country where the subsidiary is resident; state, provincial and local taxes do not qualify.
• The relief cannot reduce the combined corporation tax and external tax below the corporation tax that would have been payable had the income arisen in the State.
• Claims must be made in writing within six years of the end of the relevant accounting period, with a right of appeal to the Appeal Commissioners if the inspector refuses the claim.