– see also EU Directives

Aim

Anti-abuse

Directive shopping

Dividends

Domestic anti-abuse provisions

Elimination of double taxation

Implementation

Interaction with treaties

Inward-bound distributions

Ireland

Outward-bound distributions

Permanent establishment

Qualification requirements

Beneficial ownership

Minimum holding

Qualifying entities

Residence

Subject to tax

Qualifying distributions

Real estate investment trusts

Transparent entities

Withholding tax exemption