Withholding tax at 20% is generally applicable to payments of interest by and Irish company.\u00a0\u00a0 However there is an exception for quoted euro bonds and for payments in to the \u00a0EU or to\u00a0 a Double Taxation Treaty territory.\u00a0 Quoted euro bonds are those which carry a right to interest in a quoted and a recognised Stock Exchange.<\/p>\n
There is no obligation to withhold tax on interest on quoted euro bonds if the person \u00a0to whom payment is made is not in Ireland, payment is through certain intermediaries or or the person who is beneficial owner provided a declaration that they are non-resident.<\/p>\n
There is an exemption from the requirement to withhold tax in relation to interest paid by a qualifying company in the ordinary course of business to a person resident in an EU State or double tax treaty.\u00a0 The underlying holder must meet certain conditions.<\/p>\n
Interest on commercial paper falls outside the withholding tax obligation on the basis that it is not yearly interest.\u00a0 There is an exemption from withholding tax on commercial paper with a maturity of less than two years, held within a recognised clearing denominations of \u20ac500,000, $500,000 or equivalent in other currency.<\/p>\n
The paying agent must be situate in Ireland and the recipient must make a declaration confirming Irish residence or confirm non-Irish residence.\u00a0 Commercial paper between one and two years does not qualify as essential commercial paper for the Central Bank\u2019s purposes.<\/p>\n\n
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S.110 Entities Section 110 of the Taxes Consolidation Act allows computation of trading profits of companies which qualify for treatment on the same basis as a trading company.\u00a0 This allows deduction of expenses including interest and other funding costs. Companies may allow a deduction for profit participating interest and interest exceeding a reasonable commercial return […]<\/p>\n","protected":false},"author":1,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"_exactmetrics_skip_tracking":false,"_exactmetrics_sitenote_active":false,"_exactmetrics_sitenote_note":"","_exactmetrics_sitenote_category":0,"footnotes":""},"categories":[133],"tags":[],"_links":{"self":[{"href":"https:\/\/legalblog.ie\/wp-json\/wp\/v2\/posts\/10081"}],"collection":[{"href":"https:\/\/legalblog.ie\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/legalblog.ie\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/legalblog.ie\/wp-json\/wp\/v2\/users\/1"}],"replies":[{"embeddable":true,"href":"https:\/\/legalblog.ie\/wp-json\/wp\/v2\/comments?post=10081"}],"version-history":[{"count":4,"href":"https:\/\/legalblog.ie\/wp-json\/wp\/v2\/posts\/10081\/revisions"}],"predecessor-version":[{"id":32573,"href":"https:\/\/legalblog.ie\/wp-json\/wp\/v2\/posts\/10081\/revisions\/32573"}],"wp:attachment":[{"href":"https:\/\/legalblog.ie\/wp-json\/wp\/v2\/media?parent=10081"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/legalblog.ie\/wp-json\/wp\/v2\/categories?post=10081"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/legalblog.ie\/wp-json\/wp\/v2\/tags?post=10081"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}