Ireland: foreign tax credit, treaty withholding rates and non-resident companies (2026)

This skill answers three questions. How much credit does an Irish resident get for foreign tax? What does Ireland withhold when it pays dividends, interest or royalties abroad, and what does a treaty reduce that to? How is a company that is not resident in Ireland taxed on Irish income?

Residence, SARP, split-year treatment and the company exit tax are in ie-cross-border. The remittance basis is in ie-non-dom. Corporation tax rates and the participation exemption are in ie-corporation-tax. Branch profit attribution between related parties is in ie-transfer-pricing.

The law is the Taxes Consolidation Act 1997 (TCA 1997) as amended to Finance Act 2025. Finance Act 2026 (No. 24 of 2026, signed 15 July 2026) changes only excise. The Budget 2027 bill, Finance (No. 2) Bill 2026 (Bill 98 of 2026, initiated 19 October 2026), is not law; as initiated it does not amend Schedule 24, section 172D, section 242A or section 246(3)(h). The figures below are read from Revenue's Notes for Guidance, Finance Act 2025 edition (December 2025), from Revenue's Tax and Duty Manuals, and from the treaty texts Revenue publishes.

Who this applies to

• An Irish resident individual or company with foreign income that was taxed abroad. Credit relief under Schedule 24 is given only to a person resident in Ireland (Schedule 24, paragraph 3), with limited exceptions for EU and EEA companies trading here through a branch (paragraphs 9A, 9B, 9C).
• An Irish company or individual paying dividends, interest or royalties to a non-resident. The payer withholds and pays the tax over, unless a domestic exemption or a treaty applies.
• A company that is not resident in Ireland with Irish income: a branch or agency here, Irish rental property, or Irish interest, royalties or dividends.

Company residence is decided under section 23A (see ie-cross-border). A treaty applies only to a resident of the treaty partner who is the beneficial owner of the income.

Rates, bands and thresholds

Item	Rate or amount	Year	Source
Dividend withholding tax (DWT) on distributions by Irish resident companies (section 172A, 172B)	25%	2026	Notes for Guidance, Part 6
Withholding on yearly interest paid by a company, or paid to a person whose usual place of abode is abroad (section 246(2))	Standard rate of income tax, 20%	2026	Notes for Guidance, Part 8; Notes for Guidance, Part 2, section 15
Withholding on patent royalties and annual payments (sections 237, 238)	Standard rate of income tax, 20%	2026	Notes for Guidance, Part 8
Income tax on a non-resident company's Irish income that is outside corporation tax (section 15(1))	Standard rate, 20%	2026	Notes for Guidance, Part 2
Income tax bands, single person	20% on the first EUR 44,000, 40% on the balance	2026	Revenue: tax rates, bands and reliefs
Single person tax credit; employee (PAYE) tax credit	EUR 2,000 each	2026	Revenue: tax rates, bands and reliefs
Foreign tax credit cap, individual (Schedule 24, paragraph 5)	Foreign income times the Irish effective rate on total income	2026	Notes for Guidance, Schedules
Foreign tax credit cap, company (Schedule 24, paragraph 4)	Irish corporation tax attributable to that income; 25% of the income where it is taxed at 25%	2026	Notes for Guidance, Schedules
Surplus foreign tax on a 5% or more foreign dividend, usable against other foreign dividends (Schedule 24, paragraph 9E)	75% of the surplus on a dividend taxed at 25%; 87.5% of the surplus on a dividend taxed at 12.5% (the rest is relieved by reducing the income)	2026	Notes for Guidance, Schedules
Unilateral relief on non-treaty trading interest, royalties or leasing income (paragraphs 9D, 9DB, 9DC)	87.5% of the foreign tax, capped at the Irish corporation tax on that income (12.5% is already relieved as a deduction)	2026	Notes for Guidance, Schedules
Time limit to claim a foreign tax credit (Schedule 24, paragraph 12(2))	6 years after the end of the year of assessment or accounting period	2026	Notes for Guidance, Schedules
Minimum holding for unilateral credit and pooling on foreign dividends (paragraphs 9B, 9E)	5%	2026	Notes for Guidance, Schedules

The treaty rate table is under Cross-border points.

The taxable base

Schedule 24: the credit for foreign tax

General rule. Where a treaty allows it, foreign tax on foreign income is credited against the Irish tax on the same income (paragraph 2(1) and (2)). Without a treaty there is no credit under paragraph 2 (paragraph 2(3)); companies have the unilateral reliefs below. No credit is given for a qualified IIR or UTPR (Pillar Two top-up) under paragraph 2(4).

Individuals. The credit goes first against income tax, then any balance against USC (paragraph 2(2A), 5A).

1. Work out the Irish effective rate: total income tax payable divided by total income (paragraph 5(1)). Foreign income goes in gross, with no deduction for foreign tax (paragraph 7(4)). For a person caught by the high earners restriction, use adjusted income and the tax under section 485E.
2. The credit cannot exceed the foreign income times that effective rate.
3. If the foreign rate is higher than the Irish effective rate, the foreign income is regrossed. Net foreign income is grossed up at the Irish effective rate; the credit is the regrossed income times the effective rate; the foreign tax not credited is deducted from the income (paragraph 7(3)(c)). Revenue's worked case: EUR 1,000 gross, EUR 150 foreign tax (15%), Irish effective rate 12%. Regrossed income EUR 966; credit EUR 116; EUR 34 is deducted.
4. Foreign tax still unused after the income tax computation can be credited against USC, capped at the foreign income times the person's effective USC rate (paragraph 5A).
5. The total credit cannot exceed the income tax payable for the year (paragraph 6).

A person may elect not to take the credit and deduct the foreign tax instead (paragraph 10). The credit is normally worth more.

Companies. The credit cannot exceed the corporation tax attributable to the doubly taxed income, measured under Irish rules (paragraph 4(1), (2)). Revenue's example: German tax EUR 1,000, Irish corporation tax on the same income EUR 800, credit EUR 800. Where the income is taxed at 25%, the cap is 25% of the income (paragraph 4(4)). The company may allocate its deductions across its income and gains to its best advantage, but must allocate all of them (paragraph 4(5)). For doubly taxed trading receipts such as interest received by a financial trader, the income is a share of net trading income by gross receipts (paragraph 4(2A)). Foreign tax that cannot be credited reduces the income charged (paragraph 7(3)(c)).

Dividends from foreign companies. Credit also covers underlying tax on the profits out of which the dividend is paid, through any number of tiers, where each company is a 5% subsidiary of the one above (paragraph 9B). The relevant company must be resident in Ireland or in an EU or treaty EEA state with an Irish branch. Paragraph 9 treats a fixed-rate dividend as ordinary where the Irish company controls at least half the votes.

Unilateral relief (companies only). Where there is no treaty, Schedule 24 gives credit as if there were one:

• dividends from a foreign subsidiary, including underlying tax and a foreign QDTT (paragraph 9A);
• profits of a foreign branch, including a foreign QDTT (paragraph 9DA);
• trading interest, royalties and leasing income with foreign withholding tax (paragraphs 9D, 9DB, 9DC).

Revenue lists these as the unilateral reliefs and names no general unilateral credit for an individual (Revenue: relief).

Pooling of surplus credit (companies). Where foreign tax exceeds the Irish tax on one item, the surplus can go against Irish tax on similar items in the same accounting period:

• foreign dividends from 5% holdings: surplus on a dividend taxed at 25% goes against corporation tax on other foreign dividends of the period, and surplus on a dividend taxed at 12.5% goes only against tax on other 12.5% dividends, with any balance carried forward (paragraph 9E(2) and (3));
• foreign branch income (paragraph 9FA);
• interest from associated (25%) companies in treaty countries received in a financial trade (paragraph 9F);
• foreign trading royalties: here the unrelieved foreign tax reduces other foreign royalty income of the period, allocated as the company chooses, rather than being credited (paragraph 9DB(4) to (6));
• leasing income, carried forward against the same stream (paragraph 9DC).

Revenue also allows a carry-back of branch foreign tax that arises only from timing differences, at 87.5% of the stranded tax (TDM Part 35-02-06).

Capital gains. Schedule 24 applies to CGT through section 828. Foreign tax on a gain is credited only against Irish CGT. Foreign tax that cannot be credited under a treaty is deductible in computing the gain (section 828(4)). Where an older treaty does not cover capital gains, paragraph 9FB gives unilateral credit for foreign tax on the gain; it names Belgium, Cyprus, France, Italy, Japan, Luxembourg, the Netherlands, Pakistan and Zambia.

Tax sparing. Foreign tax given up under a foreign incentive counts as paid only where the treaty says so (section 829).

Section 826: how treaties take effect

A treaty has force of law once the Government makes an order approved by Dáil Éireann and the order is listed in Part 1 of Schedule 24A. The Multilateral Instrument (MLI) has force of law the same way, through an order listed in Part 5 of Schedule 24A (section 826(1E)). Schedule 24 gives the credit mechanics. (Notes for Guidance, Part 35)

Non-resident companies (section 25, section 1034)

• Trading here through a branch or agency: corporation tax on trading income arising directly or indirectly through the branch, income from property or rights used or held by the branch, and chargeable gains on assets used for the branch (section 25(2)). Profits are attributed to the branch under the Authorised OECD Approach for periods from 1 January 2022 (section 25A).
• Irish rental income (Case V): corporation tax from 1 January 2022, with gains on those properties also in corporation tax; development land gains stay in CGT (section 25(2A)).
• Other Irish-source income with no branch (for example interest or royalties): income tax at the standard rate of 20% (section 15(1)), usually collected by withholding at source. Gains on Irish specified assets are charged to CGT (section 29).
• Tax deducted at source from income that falls into the company's corporation tax is set against that corporation tax. It is not repaid until the liability for the period is settled (section 25(3)).
• Assessment through a representative. A non-resident can be assessed in the name of any agent, branch or representative in Ireland, with the same liability as if it were resident (sections 1034, 1035, applied to corporation tax by section 1040). An independent authorised investment manager is excluded (section 1035A).
• Dividends from Irish companies to the branch are not taxed again as distributions (section 129), with limited exceptions.

(Notes for Guidance, Part 2; Notes for Guidance, Part 45)

Domestic exemptions from Irish withholding

Dividends (section 172D). No DWT on a distribution to a non-resident beneficial owner who has a current declaration with the payer:

• an individual neither resident nor ordinarily resident in Ireland who is resident in a "relevant territory" (an EU state or a treaty country, including one whose treaty is signed but not yet in force), with a certificate from that country's tax authority;
• a company resident in a relevant territory and not controlled by Irish residents;
• a company controlled by residents of relevant territories who are not themselves controlled from outside those territories;
• a company whose principal class of shares (or its 75% parent's) is substantially and regularly traded on a recognised stock exchange in a relevant territory.

Companies self-certify. Forms and the five-year validity are in ie-cross-border.

Interest (section 246(3)). The main exemption for groups is paragraph (h): interest paid in the course of a trade or business by a company to a company resident in a relevant territory that taxes foreign interest generally, or where the treaty exempts the interest. It does not apply if the interest goes to an Irish branch of the recipient. Other paragraphs cover bank interest, section 110 companies, investment undertakings and certain State bodies.

Royalties (section 242A). No withholding on royalties paid by a company in the course of its trade or business to a company resident in an EU state or treaty country that taxes foreign royalties generally, paid for bona fide commercial reasons. The recipient is also taken out of the Irish charge. The Interest and Royalties Directive (sections 267G to 267L) exempts payments to associated EU companies.

Outbound payments defensive measures (Part 33, Chapter 5; section 817V for interest, section 817W for royalties). From Finance (No. 2) Act 2023, the exemptions above are switched off for interest, royalties and distributions paid to an associated entity in a "specified territory": a country on Annex I of the EU list of non-cooperative jurisdictions, or a no-tax or zero-tax territory. Withholding then applies at the domestic rate, or the treaty rate if a treaty applies and the conditions are met. (TDM Part 08-03-06, paragraph 1.3)

Deadlines and filing

• Foreign tax credit: claimed in the income tax return (Form 11) or the corporation tax return (CT1), within 6 years after the end of the year or accounting period (Schedule 24, paragraph 12(2)). Where the foreign or Irish liability is only finalised later, the claim or amendment can be made within 6 years of the final figures (paragraph 13).
• Interest and patent royalty withholding by an Irish company (section 239): returned for each accounting period within 9 months of its end, by day 23 of that month when filed on ROS. The tax is due with the corporation tax for the period and is treated as corporation tax. Income tax suffered on payments received can be set off.
• Treaty rate at source on interest and patent royalties: where no domestic exemption applies, the payer may withhold at the treaty rate instead of 20% on receipt of a self-certification from the payee: Form 8-3-6 Interest (section 9.1) or Form 8-3-6 Patent Royalties for an individual payee (section 9.2), certified by the payee's tax authority, or uncertified with a residence certificate (a US Form 6166 for US residents). The payer returns details of the payments to Revenue (royalties: in its CT1). The self-certification expires after 5 years or on a material change in the payee's facts. For patent royalties paid to non-resident companies Revenue applies a similar practice under TDM Part 08-01-04 (TDM Part 08-03-06, section 9 and footnote 8).
• DWT: return and payment by day 14 of the month after the distribution (see ie-cross-border).
• Non-resident company: a branch or Case V landlord files CT1 like a resident company (see ie-corporation-tax).

Penalties and interest

• Late payment of corporation tax, income tax and CGT, including withholding tax returned under section 239: interest at 0.0219% a day (section 1080). (Revenue: guidelines for charging interest on late payment)
• Missed withholding: a payer who should have withheld under section 238 or 246 is assessed for the tax (section 238(4)); the section 239 tax on an estimated assessment carries interest from the date it was due.
• Late return surcharges on Form 11 and CT1 are in ie-income-tax-form11 and ie-corporation-tax.
• Wrong treaty claim: Revenue can raise an amended assessment where foreign income was under-assessed or credit given wrongly (Schedule 24, paragraph 11).

Cross-border points

Treaty withholding rates

Maximum rate the source country may charge under each treaty, for a beneficial owner resident in the other country. The older treaties with France, Italy, Luxembourg and Japan exempt Irish dividends only from "Irish sur-tax"; Ireland's own DWT is then removed by the domestic exemption in section 172D. Rates on Irish payments rarely matter in practice where the domestic exemptions in sections 172D, 242A and 246(3)(h) apply, and they do apply to most treaty residents.

Partner	Dividends	Interest	Royalties	Source (Revenue treaty text)
United Kingdom	15%; 5% to a company controlling 10% or more of the votes	0%	0%	Synthesised text with MLI, Articles 11 to 13
United States	15%; 5% to a company owning 10% or more of the voting stock	0%	0%	1997 Convention, Articles 10 to 12
Germany	15%; 5% to a company holding directly 10% or more of the capital for 365 days	0%	0%	2011 Convention, Articles 10 to 12; 2021 Protocol
France	French dividends to Irish residents: 15%; 10% to an Irish company holding 50% or more of the capital for 365 days	0%	0%	Synthesised text with MLI, Articles 9 to 11
Netherlands	15%; 0% to a company holding directly 10% or more of the capital for 365 days, or a pension fund	0%	0%	2019 Convention, Articles 10 to 12
Luxembourg	Luxembourg dividends to Irish residents: 15%; 5% to a company (not a partnership) controlling directly 25% or more of the votes	0%	0%	Synthesised text with MLI, Articles 9 to 11
Spain	Irish dividends: exempt from Irish tax on dividends. Spanish dividends: 15%; 0% to a company controlling directly 25% or more of the votes for 365 days, under the Spanish Parent-Subsidiary rules	0%, but Spain may charge up to 10% if its domestic law taxes the interest (Protocol)	5% copyright of literary, dramatic, musical or artistic work; 8% films, tapes and other image or sound media, industrial, commercial or scientific equipment, and copyright of scientific work; 10% all other	Synthesised text with MLI, Articles 10 to 12 and Protocol
Italy	Italian dividends to Irish residents: 15%	10%	0%	Convention, Articles 9 to 11
Switzerland	15%; 0% to a company holding directly 10% or more of the capital, a pension scheme or the central bank	0%	0%	Convention, Articles 10 and 11; 2012 Protocol, new Article 9
Japan	Japanese dividends to Irish residents: 15%; 10% to an Irish company owning 25% or more of the voting shares for 6 months	10%	10%	Synthesised text with MLI, Articles 11 to 13
China	10%; 5% to a company holding directly 25% or more of the votes	10%	10%; for equipment rentals, 10% of 60% of the gross	Agreement, Articles 10 to 12
India	10%	10%	10% (also fees for technical services)	Synthesised text with MLI, Articles 10 to 12

Read on 2026-10-23. Notes:

• The Netherlands convention signed on 13 June 2019 entered into force on 29 February 2020 and has effect in Ireland from 1 January 2021 (Article 30). It replaced the 1969 convention. (Dutch treaty database)
• France, Italy, Luxembourg and Japan: the Irish side of these older treaties only exempts the dividend from "Irish sur-tax" (France: only for individuals). Irish DWT is relieved under section 172D.
• Germany: the 365-day holding condition for the 5% rate comes from the Protocol signed on 19 January 2021 (S.I. No. 508 of 2021). Revenue's dates-of-effect table gives it effect in Ireland from 1 January 2022 for income tax, corporation tax and CGT, so it applies throughout 2026. (Revenue: dates of effect of Ireland's tax treaties)
• MLI: in the six synthesised texts above (UK, France, Luxembourg, Spain, Japan, India) the MLI adds the principal purpose test and, for France and Spain only, the 365-day holding period on dividends. It changes no rate in the table.
• The US treaty has its own credit rule for a US citizen resident in Ireland (Article 24(3)). Ireland then credits only the US tax a non-citizen would pay.
• Each rate is a ceiling for the beneficial owner. Treaty anti-abuse rules apply on top: the MLI principal purpose test where the synthesised text shows it, Spain's Protocol rule denying relief to holding companies more than 50% owned by non-residents, and the "special relationship" rule limiting the rate to an arm's length amount.

Getting the treaty rate on foreign income received

Foreign tax above the treaty rate is not "foreign tax" for Schedule 24 (paragraph 1, which counts only tax for which the treaty allows credit). Reclaim the excess from the foreign authority. A Revenue certificate of residence for the claim is described in TDM Part 35-01-05.

Worked examples

Example 1: Irish resident with US dividends, higher-rate taxpayer

Siobhán is single, resident and domiciled in Ireland. In 2026 she earns a salary of EUR 90,000 and receives US dividends of EUR 10,000 gross from US shares (under 10% of any company). The US withholds 15% under Article 10(2)(b) of the treaty: EUR 1,500. She is not a US citizen.

• Total income: 90,000 + 10,000 = EUR 100,000. The dividend goes in gross (paragraph 7(4)).
• Income tax: 20% of 44,000 = 8,800; 40% of 56,000 = 22,400; total 31,200. Less credits of EUR 4,000: EUR 27,200.
• Irish effective rate: 27,200 / 100,000 = 27.2%.
• Credit cap: 10,000 times 27.2% = EUR 2,720. The US tax of EUR 1,500 is below it, so the full EUR 1,500 is credited. No regrossing, because the foreign rate (15%) is below the Irish effective rate.
• Irish income tax due: 27,200 minus 1,500 = EUR 25,700.
• The dividend bears 40% overall: EUR 1,500 in the US plus EUR 2,500 in Ireland (Irish tax on it at her marginal 40% is EUR 4,000).
• No foreign tax is left over for USC. USC and PRSI on the dividend are charged as normal; see ie-usc.

name: Irish resident, EUR 10,000 US dividend with 15% US tax, salary EUR 90,000 (2026)
inputs:
  salary: 90000
  dividend: 10000
  us_rate: 0.15
  band: 44000
  credits: 4000
steps:
  - total_income: salary + dividend
  - gross_tax: band * 0.20 + (total_income - band) * 0.40
  - tax_before_ftc: gross_tax - credits
  - effective_rate: tax_before_ftc / total_income
  - us_tax: dividend * us_rate
  - credit_cap: dividend * effective_rate
  - credit: min(us_tax, credit_cap)
  - irish_tax_due: tax_before_ftc - credit
  - irish_tax_on_dividend: dividend * 0.40 - credit
  - total_tax_on_dividend: us_tax + irish_tax_on_dividend
expected:
  total_income: 100000.00
  tax_before_ftc: 27200.00
  effective_rate: 0.272
  us_tax: 1500.00
  credit_cap: 2720.00
  credit: 1500.00
  irish_tax_due: 25700.00
  irish_tax_on_dividend: 2500.00
  total_tax_on_dividend: 4000.00

Example 2: Irish company pays EUR 100,000 interest to its German parent

An Irish trading company borrows from its German parent, which owns all of it and is resident and taxed in Germany. In 2026 it pays EUR 100,000 of yearly interest on the loan. The parent has no Irish branch.

• Default rule: a company paying yearly interest deducts 20% (section 246(2)). That would be EUR 20,000.
• Domestic exemption: the interest is paid in the course of the Irish company's business to a company resident in an EU state that taxes foreign interest generally, so section 246(3)(h) applies. No withholding. The German parent receives EUR 100,000.
• The treaty gives the same answer: Article 11(1) of the 2011 Germany convention taxes the interest only in Germany.
• The interest is not recharacterised as a distribution: section 130(2)(d)(iv) would treat interest to a non-resident 75% parent as a distribution, but section 130(2B) excludes a parent resident in another EU state. (Notes for Guidance, Part 6)
• Germany is not a specified territory, so the outbound payments defensive measures do not switch the exemption off.
• The edge case: had the lender been an associated company in a zero-tax territory, the exemption would be switched off. The company would withhold EUR 20,000, return it in its section 239 return within 9 months of the year end, and pay it with its corporation tax. Whether the interest is deductible for the payer is a separate question (see ie-corporation-tax and ie-transfer-pricing).

name: Irish company pays EUR 100,000 interest to German parent (2026)
inputs:
  interest: 100000
  domestic_rate: 0.20
  exempt_rate: 0
  treaty_rate: 0
steps:
  - wht_without_exemption: interest * domestic_rate
  - wht_actual: interest * min(exempt_rate, treaty_rate)
  - received_by_parent: interest - wht_actual
  - wht_if_specified_territory: interest * domestic_rate
expected:
  wht_without_exemption: 20000.00
  wht_actual: 0.00
  received_by_parent: 100000.00
  wht_if_specified_territory: 20000.00

Ask the client first

1. Where is the payee or the payer resident for tax, and is it the beneficial owner? Get a residence certificate.
2. For dividends: the shareholding percentage, votes or capital, and how long it has been held (treaty thresholds of 10%, 25% or 50%, and 365-day or 6-month holding periods).
3. Is the payment made in the course of a trade or business, and does the recipient have an Irish branch?
4. Is the recipient an associated entity in a no-tax or zero-tax territory, or on Annex I of the EU list?
5. For a credit claim: the gross foreign income, the foreign tax actually paid after any treaty reclaim, and the person's total Irish income for the year.
6. For a non-resident company: does it trade in Ireland through a branch or agent, or hold Irish property?

Sources

Source	URL	Read on
Revenue, Notes for Guidance TCA 1997, Schedules (Schedule 24, Schedule 24A), Finance Act 2025 edition	https://www.revenue.ie/en/tax-professionals/documents/notes-for-guidance/tca/schedules.pdf	2026-10-23
Revenue, Notes for Guidance TCA 1997, Part 35 (sections 826 to 829), Finance Act 2025 edition	https://www.revenue.ie/en/tax-professionals/documents/notes-for-guidance/tca/part35.pdf	2026-10-23
Revenue, Notes for Guidance TCA 1997, Part 2 (sections 15, 25, 25A)	https://www.revenue.ie/en/tax-professionals/documents/notes-for-guidance/tca/part02.pdf	2026-10-23
Revenue, Notes for Guidance TCA 1997, Part 6 (sections 172A, 172B, 172D)	https://www.revenue.ie/en/tax-professionals/documents/notes-for-guidance/tca/part06.pdf	2026-10-23
Revenue, Notes for Guidance TCA 1997, Part 8 (sections 238, 239, 242A, 246)	https://www.revenue.ie/en/tax-professionals/documents/notes-for-guidance/tca/part08.pdf	2026-10-23
Revenue, Notes for Guidance TCA 1997, Part 45 (sections 1032 to 1040)	https://www.revenue.ie/en/tax-professionals/documents/notes-for-guidance/tca/part45.pdf	2026-10-23
Taxes Consolidation Act 1997	https://www.irishstatutebook.ie/eli/1997/act/39/enacted/en/html	2026-10-23
Revenue, double taxation relief (unilateral relief)	https://www.revenue.ie/en/tax-professionals/tax-agreements/double-taxation-treaties/relief.aspx	2026-10-23
TDM Part 35-02-06, foreign branch double taxation relief (last reviewed May 2026)	https://www.revenue.ie/en/tax-professionals/tdm/income-tax-capital-gains-tax-corporation-tax/part-35/35-02-06.pdf	2026-10-23
TDM Part 35-01-05, certification of tax residence	https://www.revenue.ie/en/tax-professionals/tdm/income-tax-capital-gains-tax-corporation-tax/part-35/35-01-05.pdf	2026-10-23
TDM Part 08-03-06, interest and royalties without deduction of tax (last reviewed May 2026)	https://www.revenue.ie/en/tax-professionals/tdm/income-tax-capital-gains-tax-corporation-tax/part-08/08-03-06.pdf	2026-10-23
Revenue, tax rates, bands and reliefs	https://www.revenue.ie/en/personal-tax-credits-reliefs-and-exemptions/tax-relief-charts/index.aspx	2026-10-23
Revenue, guidelines for charging interest on late payment	https://www.revenue.ie/en/tax-professionals/tdm/collection/debt-management/Guidelines-for-charging-interest-on-late-payment-20240715074235.pdf	2026-10-23
Ireland-UK convention, synthesised text with MLI	https://www.revenue.ie/en/tax-professionals/documents/double-taxation-treaties/u/synthesised-text-mli-ireland-uk-dtc.pdf	2026-10-23
Ireland-US convention 1997	https://www.revenue.ie/en/tax-professionals/documents/double-taxation-treaties/u/usa-1997.pdf	2026-10-23
Ireland-Germany convention 2011 and 2021 Protocol	https://www.revenue.ie/en/tax-professionals/documents/double-taxation-treaties/g/germany-2011.pdf	2026-10-23
Ireland-Germany 2021 Protocol	https://www.revenue.ie/en/tax-professionals/documents/double-taxation-treaties/g/germany-protocol-2021.pdf	2026-10-23
Revenue, dates of effect of Ireland's tax treaties	https://www.revenue.ie/en/tax-professionals/tax-agreements/dates-of-effect/index.aspx	2026-10-23
S.I. No. 508 of 2021, Double Taxation Relief (Federal Republic of Germany) Order 2021	https://www.irishstatutebook.ie/eli/2021/si/508/made/en/print	2026-10-23
Finance Act 2026 (No. 24 of 2026)	https://www.irishstatutebook.ie/eli/2026/act/24/enacted/en/html	2026-10-23
Finance (No. 2) Bill 2026, as initiated	https://data.oireachtas.ie/ie/oireachtas/bill/2026/98/eng/initiated/b9826d.pdf	2026-10-23
Ireland-France convention, synthesised text with MLI	https://www.revenue.ie/en/tax-professionals/documents/double-taxation-treaties/f/synthesised-text-mli-ireland-france-dtc.pdf	2026-10-23
Ireland-Netherlands convention 2019	https://www.revenue.ie/en/tax-professionals/documents/double-taxation-treaties/n/netherlands-2.pdf	2026-10-23
Netherlands treaty database, Ireland convention 2019 (entry into force)	https://verdragenbank.overheid.nl/en/Treaty/Details/012626	2026-10-23
Ireland-Luxembourg convention, synthesised text with MLI	https://www.revenue.ie/en/tax-professionals/documents/double-taxation-treaties/l/synthesised-text-mli-ireland-luxembourg-dtc.pdf	2026-10-23
Ireland-Spain convention, synthesised text with MLI	https://www.revenue.ie/en/tax-professionals/documents/double-taxation-treaties/s/synthesised-text-mli-ireland-spain-dtc.pdf	2026-10-23
Ireland-Italy convention	https://www.revenue.ie/en/tax-professionals/documents/double-taxation-treaties/i/italy.pdf	2026-10-23
Ireland-Switzerland convention	https://www.revenue.ie/en/tax-professionals/documents/double-taxation-treaties/s/switzerland.pdf	2026-10-23
Ireland-Switzerland 2012 Protocol	https://www.revenue.ie/en/tax-professionals/documents/double-taxation-treaties/s/switzerland-protocol-2.pdf	2026-10-23
Ireland-Japan convention, synthesised text with MLI	https://www.revenue.ie/en/tax-professionals/documents/double-taxation-treaties/j/synthesised-text-of-the-mli-and-the-ireland-japan-double-taxation-convention.pdf	2026-10-23
Ireland-China agreement	https://www.revenue.ie/en/tax-professionals/documents/double-taxation-treaties/c/china.pdf	2026-10-23
Ireland-India convention, synthesised text with MLI	https://www.revenue.ie/en/tax-professionals/documents/double-taxation-treaties/i/synthesised-text-mli-ireland-india-dtc.pdf	2026-10-23

Not yet confirmed: how an individual's foreign tax on income from a country with no treaty is relieved (Revenue's unilateral relief list covers companies and CGT only, and Notes for Guidance say Revenue extends a practice to individuals without stating its terms); the Irish treaty rates for Irish-source dividends to France, Italy, Luxembourg and Japan, where the treaty names only "Irish sur-tax" and relief comes from section 172D; whether Finance (No. 2) Bill 2026 is enacted as initiated.

Contributed by Ryan Duguid.