Royalties paid under double taxation arrangements in full, or after deduction at reduced rate.

FA02/S96 introduced ICTA88/S349E for payments made on or after 1 October 2002. This legislation is now in ITA07/PART15/CHAPTER8.

ITA07/S911 allows companies to pay royalties overseas and deduct only the reduced rate of tax prescribed by the relevant double taxation agreement without seeking prior clearance from the Revenue.

The conditions for the scheme are:

payment is made on or after 1 October 2002

ITA07/Part15 Chapters 6 or 7 (deduction of tax) would have applied to the royalty payment, and

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