Many foreign companies opening subsidiaries or branch offices in another country are interested if any double taxation agreements have been signed by their resident country and the country they have opened a company in. Ireland is one of the countries with an extended network of double taxation treaties on all continents. Ireland has currently signed 72 double taxation agreement and 68 of them are enforced. At the moment, Ireland is negotiating with other countries in order to conclude more taxation conventions. The double taxation agreements Ireland signed refer to the direct taxes: the income tax, the corporate tax and the capital gains tax. Ireland is also one of the countries that amended its double taxation agreements with the new OECD (Organization for Economic Co-operation and Development) provisions on tax transparency.
Almost all of Ireland’s double taxation agreements provide a zero withholding tax on interest for certain partner countries, or zero tax rates for certain types of interests only. The exceptions from this rule are Australia, Chile, Israel and Turkey that benefit from reduced tax rates on interests. Other double tax treaties provide tax exemptions for royalty payments made by Irish companies to foreign shareholders.
According to the Irish Taxes Consolidation Acts (TCA) adopted in 1997, direct taxes will benefit from relief against double taxation. Among the incomes relieved from double taxation are dividends from foreign subsidiaries, capital gains on foreign assets and profits earned by foreign branch offices in Ireland.
As an EU member state, Ireland also offers tax relief under the EU Parent-Subsidiaries Directive, 90/435/EEC, under the EU Interests and Royalties Directive, 2003/49/EC and the EU Mergers Directive, 90/434/EEC.
Among the countries Ireland has double taxation treaties with are:
Ireland has also concluded double taxation agreements with Russia and New Zealand.
You can contact us if you want to open a company and want to know if your country has a tax treaty with Ireland. Our specialists in company incorporation in Ireland will also help you with the business registration procedure.