On 22 December 2022, the Irish Revenue published eBrief No. 221/22 on payment and receipt of interest and royalties without deduction of income tax. Accordingly, Tax and Duty Manual Part 08-03-06 – Payment and Receipt of Interest and Royalties without Deduction of Income Tax – has been updated to:

  • clarify Revenue’s interpretation of the meaning of bona fide banking business in the State; and
  • modify, in certain circumstances, the Self-Certification process in relation to the application of withholding tax on certain payments of interest and royalties at the applicable DTA rate under the terms of a double taxation agreement.