Tax Treatment of Foreign Source Dividends

Irish companies will be taxed at the 12.5% rate in respect of foreign dividends received on or after 1 January 2012 where such dividends are paid out of trading profits of privately held companies in countries which have joined the OECD Convention on Mutual Administrative Assistance in Tax Matters (section 52). Such countries include Ukraine and Brazil. This brings the tax treatment of such dividends in line with the treatment of dividends received by an Irish resident company from either; a trading company resident in an EU Member State, or a territory with which Ireland has concluded a tax treaty, or which is part of a quoted group.