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ARTICLE · 15 OCTOBER 2024

Ireland Introduces A Participation Exemption For Foreign Distributions

Arthur Cox
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The new rules have been the subject of lengthy stakeholder consultations and form part of a broader modernisation of Ireland's corporate tax code.

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Fintan Clancy
Fintan Clancy
Ailish Finnerty
Ailish Finnerty
Orlaith Kane
Orlaith Kane
David Kilty
David Kilty
Mary Dineen
Mary Dineen
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The long-awaited legislation for the introduction of a participation exemption for non-Irish dividends and distributions was included in this year's Finance Bill.

The new rules have been the subject of lengthy stakeholder consultations and form part of a broader modernisation of Ireland's corporate tax code. The Minister for Finance has indicated that further work will be carried out on a similar exemption for branch profits and a consultation on interest deductibility which we welcome.

Arthur Cox Engagement

Arthur Cox engaged with the Department throughout the stakeholder engagement over the past year and particularly in relation to the draft legislative text that was published in August. Our contributions sought to ensure that a broad, competitive and easy to administer regime was introduced; one that is no more restrictive than our EU partners.

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This article contains a general summary of developments and is not a complete or definitive statement of the law. Specific legal advice should be obtained where appropriate.

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