Dividend Withholding Tax (DWT)

Exemptions for non-residents

A qualifying non-resident person can claim an exemption from DWT. However, this is subject to outbound payments defensive measures.

Qualifying non-resident persons subject to defensive measures are:

• Persons, other than companies, who are neither resident nor ordinarily resident in the State. These persons can include superannuation funds and charities. They must be resident for tax purposes in a relevant territory which is:
  • a European Union (EU) Member State, or an European Economic Area (EEA) State, other than Ireland
  • a country with which Ireland has a Double Taxation Agreement. 
• Companies resident in a relevant territory which are neither directly nor indirectly controlled by an Irish resident person.
• Companies not resident in the State which are controlled by persons resident for tax purposes in a relevant territory.
• Companies not resident in the State, and their principal class of shares, which are substantially and regularly traded on:
  • a stock exchange in the State
  • one, or more than one, recognised stock exchanges in a relevant territory or territories
  • such other stock exchange as may be approved of by the Minister for Finance.
• Companies not resident in the State who are a 75% subsidiary of another company. Where the parent company’s principal class of shares are substantially and regularly traded on either:
  • a stock exchange in the State
  • one, or more than one, recognised stock exchanges in a relevant territory or territories
  • such other stock exchange as may be approved of by the Minister for Finance.
• Companies not resident in the State which are wholly owned by two or more companies where their principal class of shares are substantially and regularly traded on either:
  • a stock exchange in the State
  • one, or more than one, recognised stock exchanges in a relevant territory or territories
  • such other stock exchange as may be approved of by the Minister for Finance.

For further information, please see Tax and Duty Manual Part 33-05-01.

To claim an exemption

Exemption from DWT is not an automatic entitlement. To claim an exemption, a qualifying non-resident person must complete the relevant exemption declaration form:

• Form V2B, if they are a company
• Form V2A, if they are an individual
• Form V2C, if they are a body of persons (and not an individual or company).

Forms V2A and V2C must be certified by the tax authority of the country in which the qualifying non-resident person is resident.

The exemption is valid until 31 December of the fifth year following the year that exemption was issued. If the qualifying non-resident person wants the DWT exemption to continue, they must renew the exemption before the end of this period.

An exempt shareholder must provide the exemption declaration form to either:

• the Irish company or Authorised Withholding Agent (AWA)
• or
• the Qualifying Intermediary (QI) that made the dividend payment.

There is a simplified process for residents of the United States (US) to receive American Depository Receipts (ADRs) dividends without deduction of DWT. Please contact the DWT Unit for further information.

Next: Refunds for non-residents