Ireland signed a double tax treaty with Armenia on July 14, 2011. It allows for withholding tax of 0 % on dividends if the benefi cial owner is a company (other than a partnership) which holds at least 25 % of the capital for a period of at least 2 years, 5 % if the benefi cial owner is a company (other than a partnership) which holds at least 10 % capital or 15 % withholding tax in all other cases. Withholding tax on interest shall not exceed 5 % if it is paid in respect of a loan of any kind granted by a banking institution or 10 % in all other cases. Withholding tax on royalties shall not exceed 5 % of the gross amount of the royalties. Capital gains shall be taxable only in the State the individual is resident.