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HMRC internal manual

Double Taxation Relief Manual

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HM Revenue & Customs
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Double Taxation Relief Manual: Guidance by country: Ireland: Dividends

A United Kingdom resident recipient beneficially entitled to a dividend from an Irish company will pay the following reduced rates of Irish withholding tax:

  • Under the EU Parent/Subsidiary Directive, 0% if the resident is a UK company holding at least 25% of the capital of the company paying the dividend. The level of control required to gain exemption is 20% from 1 January 2005, 15% from 1 January 2007 and 10% from 1 January 2009;
  • Under the UK/Ireland treaty, 5% if the recipient is a United Kingdom resident company not within the above, but controlling directly or indirectly 10% of the voting power of the Irish company
  • all other cases: 15%.