Revenue eBrief No. 119/24
11 April 2024
Tax and Duty Manual revisions - Outbound Payment Defensive Measures
Tax and Duty Manual Part 08-03-11 - Interest in respect of wholesale debt instruments - has been updated.
Finance (No.2) Act 2023 inserted Chapter 5 ‘Outbound payments defensive measures’ in Part 33 of the Taxes Consolidation Act 1997 (‘TCA 1997’). The Chapter provides for the implementation of defensive measures by way of withholding taxes, on outbound payments of interest and royalties, and on the making of distributions, in certain circumstances. A new Tax and Duty Manual (TDM) Part 33-05-01 was issued on 26 March 2024 which provides guidance on the defensive measures.
The following Tax and Duty Manuals have been revised to reflect the new measures:
- Part 02-02-01 ‘Corporation Tax: General Background - Dividends and Portfolio Investors’.
- Part 06-04-02 ‘Distributions out of certain exempt profits or gains or out of certain relieved income’.
- Part 06-08A-01 ‘Dividend Withholding Tax (DWT) – Details of Scheme’.
- Part 06-08B-01 ‘Technical Guidance notes in relation to the operation of Dividend Withholding Tax’.
- Part 08-01-04 ‘Treatment of Certain Patent Royalties Paid to Companies Resident Outside the State’.