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5.5. Source Rules with Respect to Income Derived by Non-Residents

Non-residents are subject tax on income sourced from Ireland. The following covers various income types and the general source rules for each.

Specific Source Rules for Income Types

Business Profits

The source of business profits is deemed to be Ireland sourced if the underlying operations are carried out in Ireland.

Income from Immovable Property

Income in connection with immovable property or gains from the sale of immovable property is deemed Ireland sourced if the property is situated in Ireland.

Dividend Income

Dividend income is deemed Ireland sourced if the company paying the dividends is resident in Ireland.

Interest Income

Interest Income is deemed Ireland sourced if the payer of the interest is resident in Ireland. In addition, if the payer of the interest is not a resident in Ireland, but has a PE in Ireland which bears the interest, it will be deemed Ireland sourced.

Royalty Income

Royalty income is generally deemed Ireland sourced if the payer is resident in Ireland, or if payment is made in connection with a PE in Ireland.