Irish Revenue Clarifies that REITs are Not Eligible for Dividend Withholding Tax Exemption under Parent-Subsidiary Directive

Irish Revenue has issued eBrief No. 207/22 concerning updates to the Tax and Duty Manual on Real Estate Investment Trusts (REITs). In regard to dividend withholding tax (DWT) for non-resident investors in an Irish REIT, an updated footnote is provided to clarify that although the Parent-Subsidiary Directive could theoretically apply, a REIT would not meet the requisite conditions required for the application of the Directive. This is because REITs are not subject to corporation tax and, the…