I am issuing a FOI request in relation to the introduction of relief from withholding tax on royalties. Certain measures were introduced as follows: Section 55 Finance Act 2010 provided that withholding tax was not to apply to royalties paid by a company in the course of a trade or business to a company resident in a treaty country. Later in 2010 a statement of practice was issued by Revenue entitled "Corporation Tax Statement of Practice SP - CT 01/10 Treatment of Certain Patent Royalties Paid to Companies Resident Outside the State”. This provided for no withholding tax on patent royalties in certain circumstances. I would like to request information (letters, emails, records of internal and external communications, minutes of internal and external meetings, phone calls, submissions, memos and briefing papers to ministers) relating to the following: 1. the reasons behind the introduction of the measures outlined above, including where those measures were considered in tandem; 2. any representations made to the Department of Finance and/or Revenue relating to the desirability or otherwise of introducing the measures outlined above by any of the following: any semi-state entity such as the IDA, groups, associations, private individuals, professional services firms or corporate entities; 3. any consideration of the representations at 2 above by the Department of Finance