(January 29, 2015) 

On January 29, 2015 the Irish Tax and Customs issued 7 eBriefs (eBrief 08/15 through -14/15). eBrief No. 09/15 is titled “Foreign Dividends – Additional Foreign Tax Credit”.

 

The purpose of eBrief 09/15 is to clarify Irish Finance Act changes made in 2013 to the calculation of foreign tax credits in respect of certain foreign dividends received by Irish companies. Following the findings of the CJEU in the Test Claimants in the FII Group Litigation (ECLI:EU:C:2012:707), the calculation of double taxation relief for foreign tax suffered on dividend income was enhanced in the Irish Finance Act 2013, to allow for an additional foreign tax credit in certain circumstances. Amendments were made refining the relief in Finance Act (No.2) 2013, as some restrictions had emerged from the operation of the legislation in practice.

 

The eBrief a.o. elaborates on: 

  • Finance Act 2013 and Finance Act (No.2) 2013 provisions;

  • Dividends paid through intermediate companies;

  • Effect of group relief;

  • Commencement of Finance Act (No. 2) 2013.

For further information click here to be forwarded to eBrief 09/15 as published on the website of the Irish Tax and Customs.

 

The other eBriefs that were published by the Irish Tax and Customs on January 29, 2015 are:

 

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