Irish Revenue has issued eBrief No. 025/23 concerning updates to Tax and Duty Manual Part 08-02-01 – Charges on income for corporation tax purposes.
The first update concerns the deduction of interest expenses in cases where withholding tax relief is provided under an applicable tax treaty. Charges on income paid to non-residents are deductible from profits in the same way as if they were paid to a company resident in the State. However, a payment to a non-resident will not be treated as a…