On April 14, 2020, Irish Revenue issued a note on the revised tax treatment of royalty income under the provisions of the Ireland-Lithuania tax treaty.
Ireland’s tax treaty with Lithuania came into effect in 1999, which notes that the tax treatment of royalty income may be revised if more favorable terms are subsequently agreed by Lithuania with another OECD country.
Lithuania recently agreed such terms with Japan and those terms are now to apply to the Ireland-Lithuania tax treaty with effect from January 1, 2019.
Tax and Duty Manual Part 35-01-12 has been created to provide details.
See Part 35-01-12