On 26 September 2017, Irish Revenue published guidance on dividend withholding tax (DWT) with some exceptions and stated that resident companies must withhold tax on dividend payments and other distributions that they make. Qualifying Irish resident persons, known as excluded persons, are entitled to an exemption from DWT.

Excluded persons are:

  • companies
  • pension schemes
  • qualifying Employee Share Ownership Trusts (ESOTs)
  • Collective Investment Undertakings (CIUs)
  • charities
  • bodies established and existing for the sole purpose of promoting athletic or amateur games or sports
  • designated brokers in relation to Special Portfolio Investments Accounts (SPIAs)
  • qualifying fund managers in relation to Approved Retirement Funds (ARFs) or Approved Minimum Retirement Funds (AMRFs)
  • Irish Exempt Unit Trusts
  • Irish Personal Retirement Savings Account (PRSA) Administrators
  • permanently incapacitated individuals
  • trustees of a trust fund
  • Thalidomide victims.