Irish Tax Appeals Commission Holds Withholding Tax on Royalties Received May be Deducted Prior to Finance Act 2019 Amendment

On 30 June 2025, the Irish Tax Appeals Commission published a determination on the deduction of withholding tax on royalties received. The determination was made after hearing an appeal concerning a company's attempt to deduct foreign royalty withholding tax from its Irish corporation tax. The core dispute revolves around whether this foreign withholding tax should be treated as a deductible business expense under Section 81 of the Taxes Consolidation Act 1997 (TCA 1997), or if it is solely …