Irish High Court Overturns Tax Appeals Commission Determination that Withholding Tax on Royalties Received May be Claimed as a Deduction

The Irish High Court issued a judgment on 12 May 2026 concerning the tax treatment of Foreign Royalty Withholding Tax (FWHT) incurred by Accenture Global Solutions Limited (an Irish tax-resident company) on its international intellectual property licensing activities. Because Accenture was in a loss-making position for Irish corporation tax purposes during the relevant period, its foreign tax credit calculation as per the standard double-taxation/foreign tax credit regime under Schedule 24 o…