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The first-time income tax treaty between Greece and Ireland and the related protocol, signed on 24 November 2003, entered into force on 29 December 2004. The new treaty generally applies from 1 January 2005. — Orbitax Tax News & Alerts

The maximum rates of withholding tax are:

-   15% in dividends in general, but 5% if the beneficial owner is a company that holds directly at least 25% of the voting power in the company paying the dividends;
-   5% on interest; and
-   5 % on royalties;

Both states provide for the credit method and exemption with progression method to avoid double taxation. Both states also grant a credit in respect of the underlying corporate tax if the recipient company controls directly or indirectly at least 10% of the voting power in the company paying the dividends.

The treaty makes no specific reference to special tax regimes in either Greece or Ireland and it is assumed that the treaty applies to entities qualifying for any such regimes.