The reason why Ireland is such an attractive option for the exploitation of royalties is that, generally speaking, no withholding tax is applicable to outgoing royalties (except on patent and mining royalties, but even these may be exempt under certain circumstances).

For many licensing structures, Ireland will be the best location for an intermediary licensing company for the exploitation of all types of intellectual property. With its new, convenient capital allowance regime, Ireland is now an ideal location for developing, holding and exploiting IP. It is important to remember that every case is different, and appropriate advice must always be sought.

https://www.confiduss.com/en/services/solutions/corporate/royalty/