Taxes Consolidation Act, 1997 (Number 39 of 1997)
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267J Credit for foreign tax.
(1) Where interest or royalties are received by a company resident in the State from an associated company, credit shall be allowed for—
(a) any withholding tax charged on the interest or royalties by Greece or Portugal, and
(b) any withholding tax charged on the royalties by Spain,
pursuant to the derogations provided for in Article 6 of the Directive against corporation tax in respect of the interest or royalties to the extent that credit for such withholding tax would not otherwise be allowed.
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(2) Where by virtue of paragraph (a) a company is to be allowed credit for tax payable under the laws of a Member State other than the State, Schedule 24 shall apply for the purposes of that paragraph as if that paragraph were arrangements providing that the tax so payable shall be allowed as a credit against tax payable in the State.
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(2) Where by virtue of subsection (1) a company is to be allowed credit for tax payable under the laws of a Member State other than the State, Schedule 24 shall apply for the purposes of that subsection as if that subsection were arrangements providing that the tax so payable shall be allowed as a credit against tax payable in the State.
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(3) This section applies without prejudice to a provision of a bilateral agreement.
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