The Revenue Commissioners have been largely unsuccessful in amending the terms of a High Court tax appeal against Getty Images. The challenge relates to whether Getty, one of the world’s largest suppliers of stock images to newspapers, magazines, advertising campaigns, films, television programmes, books, and websites, could deduct foreign royalty withholding tax (RWHT) as a business expense under Irish tax law. Headquartered in Seattle in the US, the group trades globally and holds its intellectual property in an Irish subsidiary located in Carrickmines, Dublin, called Getty Images International. The group licenses images out to affiliated entities and third-party customers in more…

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