On 10 September 2024, the Irish Tax Appeals Commission issued a determination on the deduction of withholding tax on dividends received. The particular issue in the determination is whether foreign withholding taxes, incurred by the Appellant on dividend payments that it received as a consequence of its holding shares in foreign based companies, constitute expenses that are deductible under Section 81 of the Taxes Consolidation Act 1997 (TCA) for the purpose of calculating its profits or gains chargeable to corporation tax. The Appellant is an Irish resident special purpose company established to issue exchange traded securities. In so doing, it...