List of countries with which Ireland has concluded double taxation treaties and the royalty withholding tax rates
| Recipient |
Patents, Royalties
% |
| Resident Companies |
20 |
| Resident individuals |
20 |
Non-resident companies and individuals:
Non-treaty countries |
20 |
| Recipient |
Patents, Royalties |
| Treaty Countries |
% |
| Australia |
10 |
| Austria |
Nil |
| Belgium |
Nil |
| Bulgaria |
10 |
| Canada |
Nil (b)/10 |
| China, P.R |
10(c)/10(d) |
| Croatia |
10 |
| Cyprus* |
Nil/5(e) |
| Czech Republic |
10 |
| Denmark |
Nil |
| Estonia |
5(d)/10 |
| Finland |
Nil |
| France* |
Nil(f) |
| Germany |
Nil |
| Greece |
5 |
| Hungary |
Nil |
| Iceland |
Nil(i)/10 |
| India |
10 |
| Israel |
10 |
| Italy* |
Nil |
| Japan |
10 |
| Korea, Rep. of |
Nil |
| Latvia |
5(d)/10 |
| Lithuania |
5(d)/10 |
| Luxembourg |
Nil |
| Malaysia |
8 |
| Mexico |
10 |
| Netherlands |
Nil |
| New Zealand |
10 |
| Norway |
Nil |
| Pakistan |
Nil |
| Poland |
Nil(a)/10 |
| Portugal |
10 |
| Romania |
0 (j)/3 |
| Russia |
Nil |
| Slovak Republic |
Nil/10(c) |
| Slovenia |
5 |
| South Africa |
Nil |
| Spain |
5(g)/8(h)/10 |
| Sweden |
Nil |
| Switzerland |
Nil |
| United Kingdom |
Nil |
| United States |
Nil |
| Zambia |
Nil |
Ireland is currently negotiating treaties with the following countries:
| Argentina |
Chile** |
Egypt |
| Kuwait |
Malta |
Morocco |
| Singapore |
Tunisia |
Turkey |
| Ukraine |
|
|
* These treaties are currently under renegotiation.
** Awaiting ratification by Chile.
The numbers in parentheses refer to the following numbered Notes.
Notes:
a. Applies in the case of technical services (see Ireland/Poland double taxation treaty).
b. Copyright royalties and other like payments made in respect of the production or reproduction of any literary, dramatic, musical or artistic work (but not including royalties in respect of motion picture films and films or video tapes for use in connection with television) – otherwise domestic rate will apply.
c. For technical royalties or for information concerning industrial, commercial or scientific experience.
d. For use of industrial, scientific, or commercial equipment. In the case of China, the rate is 10% of the adjusted amount of the royalties adjusted amount means 60% of the gross amount of the royalties.
e. For films (Not TV).
f. Excluding films domestic rate applies (see France/Ireland double taxation treaty).
g. Literary, dramatic, musical or artistic copyrights.
h. Films, tapes, and lease payments.
i. For technical royalties, royalties for computer software and patents or for information concerning industrial, commercial or scientific experience.
j. Any copyright of literary, artistic or scientific work including motion pictures or films, recordings on tape or other media used for radio or television broadcasting or other means of reproduction or transmission
The above details are in general subject to any special relationship that may exist between the payer and the recipient, and it is assumed that the recipient does not have a permanent establishment (taxable presence) in the other Contracting State.
Appendix II - 0% on patent royalty income | Appendix IV