Home Knowledge Mitigating Withholding Tax Leakages – The Use of Dual Structures in an Irish Tax Context

Mitigating Withholding Tax Leakages – The Use of Dual Structures in an Irish Tax Context

September 24, 2010

The purpose of this memorandum is to outline the current Irish tax regime as it pertains to Irish Regulated Collective Investment Funds and the ability of such funds to avail of Ireland’s double taxation agreement (each a “DTA”)  network.  Where the mitigation of foreign withholding taxes is not possible through the use of a DTA, this memorandum outlines some structural planning alternatives that may be used as an alternative.