Although Irish tax law imposes an obligation on companies generally, and on others who pay interest to persons whose usual place of abode is outside Ireland, to withhold tax from certain payments of interest, there are extensive carve-outs from this withholding obligation in the case of outbound interest payments
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The new guidance is not meant to reflect a substantial change to UK law, but the requirement that tax advice is ‘likely to be correct’ imposes unrealistic expectations
China and a clutch of EU nations have voiced dissent after Estonia shot down the US side-by-side deal; in other news, HMRC has awarded companies contracts to help close the tax gap