Revenue has issued eBrief No. 43/12 which sets out their position in relation to interest payments, section 246 TCA1997, and territories providing for a remittance basis of taxation.

Interest payments made under section 246(3)(h)(I) TCA 1997 to a company that is resident for tax purposes in the relevant territory (as defined in that section) and is payable by the relevant person to an account located in the relevant territory, will be treated by Revenue as exempt from withholding tax (section 246(3)(h)(I) TCA 1997) and income tax (section 198(1)(c)(ii)(I) TCA 1997)

However, where the interest is not payable by the relevant person to an account located in the relevant territory it will be subject to withholding tax and chargeable to income tax.

Further details are set out in Revenue eBrief No. 43/12 which is available on here.