S.I. No. 428/1994 - Double Taxation Relief (Taxes on Income) (Russian Federation) Order, 1994. Skip to content Disclaimer Feedback Helpdesk Gaeilge Léim go dtí an t-ábhar Séanadh Aiseolas Deasc chabhr

Article 7or Article 14, as the case may be, shall apply.

1. Where a company which is a resident of a Contracting State derives profits or income from the other Contracting State, that other State may not impose any tax on the dividends paid by the company, except insofar as such dividends are paid to a resident of that other State or insofar as the holding in respect of which the dividends are paid is effectively connected with a permanent establishment or a fixed base situated in that other State. That other State cannot subject to tax the undistributed profits of this company even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other State. ARTICLE 11 Interest
2. Interest arising in a Contracting State and paid to a resident of the other Contracting State shall be taxable only in that other State if such resident is the beneficial owner of the interest.
3. The term "interest" as used in this Agreement means income from debt claims of every kind, unless described in paragraph 3 of Article 10, and in particular, income from government securities and income from bonds or debentures, including premiums or prizes attaching to such securities, bonds or debentures as well as all other income that is treated as income from money lent by the taxation law of the Contracting State in which the income arises. Penalty charges for late payment shall not be regarded as interest for the purposes of this Article.
4. The provisions of paragraph 1 of this Article shall not apply if the beneficial owner of the interest, being a resident of a Contracting State, carries on business in the other Contracting State in which the interest arises, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the interest is effectively connected with such permanent establishment or fixed base.

Article 7or Article 14, as the case may be, shall apply.

1. Interest shall be deemed to arise in a Contracting State when the payer is a State power or an administrative authority created in that State or a resident of that State. Where, however, the person paying the interest, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the indebtedness on which the interest is paid was incurred, and such interest is paid by such permanent establishment or fixed base, then such interest shall be deemed to arise in the State in which the permanent establishment or fixed base is situated.
2. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the interest, having regard to the debt-claim for which it is paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement. ARTICLE 12 Royalties
3. Royalties arising in a Contracting State and paid to a resident of the other Contracting State shall be taxable only in that other State if such resident is the beneficial owner of the royalties.
4. The term "royalties", as used in this Article, means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work (including films, recordings on tape or other media used for radio or television broadcasting or other means of reproduction and transmission), any patent, trade mark, design or model, plan, computer programme, secret formula or process, or for information concerning industrial, commercial or scientific experience.
5. The provisions of paragraph 1 of this Article shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base.

Article 7or Article 14, as the case may be, shall apply.

4. Royalties shall be deemed to arise in a Contracting State when the payer is a State power or an administrative authority created in that State or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation to pay the royalties was incurred and such royalties are borne by that permanent establishment or fixed base, then such royalties shall be deemed to arise in the Contracting State in which the permanent establishment or fixed base is situated. 5. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such a case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement. ARTICLE 13 Gains from Alienation of Property 1. Gains derived by a resident of a Contracting State from the alienation of immovable property referred to in Article 6 of this Agreement and situated in the other Contracting State may be taxed in that other State. 2. Gains derived by a resident of a Contracting State from the alienation of, ( a ) movable property of a permanent establishment which that person has in the other Contracting State, including such gains from the alienation of such permanent establishment (alone or with the whole entity of which it is a permanent establishment), or ( b ) movable property pertaining to a fixed base which that person has in the other Contracting State for the purpose of performing independent personal services, including such gains from the alienation of such fixed base, or ( c ) shares, rights or an interest in a company, in any other legal person or in a partnership (other than shares, rights or interests which fall within sub-paragraph (

1. a)or (
2. b)of this paragraph) the assets of which consist to the extent of 50 per cent or more of, or of rights in, (
3. i)immovable property situated in the other Contracting State, or (
4. ii)shares in a company the assets of which consist to the extent of 50 per cent or more of, or of rights in, immovable property situated in the other Contracting State, may be taxed in the other Contracting State in which such permanent establishment, fixed base or immovable property, as the case may be, is situated. 3. Gains derived by a resident of a Contracting State from the alienation of means of transport operated in international traffic, or movable property pertaining to the operation of such means of transport, shall be taxable only in the other Contracting State if the place of effective management of that operation is situated in that other State. 4. Gains from the alienation of any property, other than that referred to in the preceding paragraphs of this Article, shall be taxable only in the Contracting State of which the alienator is a resident. ARTICLE 14 Income from Independent Personal Services 1. Income derived by an individual who is a resident of a Contracting State from the performance of independent personal services shall be taxable only in that State, unless ( a ) such services are performed or were performed in the other Contracting State; and ( b ) the income is attributable to a fixed base which he has or had available to him in that other State. The income attributable to that fixed base may be taxed in that other State in accordance with principles similar to those of Article 7 of this Agreement for determining the amount of business profits and attributing business profits to a permanent establishment. 2. The term "independent personal services" includes especially independent scientific, literary, artistic, educational or teaching activities, as well as the independent activities of physicians, lawyers, engineers, architects, dentists and accountants. ARTICLE 15 Income from Employment 1. Subject to the provisions of Articles 16, 18, 19 and 21 of this Agreement, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State. 2. Notwithstanding the provisions of paragraph 1 of this Article, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if all of the following conditions apply: ( a ) the recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 days in the tax year concerned of that other State; and ( b ) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other Contracting State; and ( c ) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other Contracting State. 3. Notwithstanding the preceding provisions of this Article, salaries, wages and other similar remuneration derived in respect of an employment exercised aboard a ship, aircraft or any other means of transport operated in international traffic may be taxed in the Contracting State in which the place of effective management of the operation is situated. ARTICLE 16 Directors' Fees Directors' fees and other similar payments derived by a resident of a Contracting State in his capacity as a member of the board of directors or similar body of a company which is a resident of the other Contracting State may be taxed in that other State. ARTICLE 17 Income of Artistes and Athletes 1. Notwithstanding the provisions of Articles 14 and 15 of this Agreement, income derived by a resident of a Contracting State as an entertainer, such as a theatre, motion picture, radio or television artiste, or a musician, or as an athlete, from his personal activities as such exercised in the other Contracting State, may be taxed in that other Contracting State. 2. Where income in respect of personal activities exercised by an entertainer or athlete in his capacity as such accrues not to the entertainer or athlete himself but to another person, that income may, notwithstanding the provisions of Articles 7, 14 and 15 of this Agreement, be taxed in the Contracting State in which the activities of the entertainer or athlete are exercised. ARTICLE 18 Pensions 1. Pensions and other similar remuneration (which may include an annuity) paid to a resident of a Contracting State may be taxed only in that Contracting State. 2. The term "annuity" means a stated sum payable periodically at stated times during life or during a specified or ascertainable period of time under an obligation to make the payments in return for adequate and full consideration in money or money's worth. ARTICLE 19 Income from Government Service 1. Remuneration, other than a pension, paid by a State power or administrative authority to an individual in respect of services rendered to that power or authority in the discharge of functions of a governmental nature shall be taxable only in that State. 2. However, such remuneration shall be taxable only in the other Contracting State if the services are rendered in that State and the individual is a resident of that State who: (
5. i)is a citizen of that State; or (
6. ii)did not become a resident of that State solely for the purpose of rendering the services. 3. The provisions of Articles 15 and 16 of this Agreement shall apply to remuneration in respect of services rendered in connection with a business carried on by a State power or administrative authority. ARTICLE 20 Payments to Students and Apprentices Payments which students or business apprentices who are or were immediately before visiting a Contracting State residents of the other Contracting State and who are present in the first-mentioned State solely for the purpose of their education or training receive for the purpose of their accommodation, education or training shall not be taxed in that first-mentioned State provided that such payments arise from sources outside that State. ARTICLE 21 Payments to Teachers and Researchers 1. Teachers or researchers who are or were immediately before visiting a Contracting State residents of the other Contracting State and who are at present in the first-mentioned State solely for the purpose of teaching, continuing their education, lecturing or carrying out research work at the invitation of a university, college or any other recognised educational or research institute in the first-mentioned State shall be exempt from tax on any remuneration for such teaching or lecturing, or research work, for a period not exceeding two years from when they first visited that Contracting State. An individual shall be entitled to the benefits of this Article only once. 2. The preceding provisions of this Article shall not apply to remuneration which a teacher or researcher receives for carrying on research if the research is undertaken primarily for the private benefit of a specific person or persons. ARTICLE 22 Other Income 1. Items of income of a resident of a Contracting State, wherever arising, not dealt with in the foregoing Articles of this Agreement shall be taxable only in that Contracting State. 2. The provisions of paragraph 1 of this Article shall not apply to income, other than income from immovable property as defined in paragraph 2 of Article 6 of this Agreement, if the beneficial owner of the income, being a resident of a Contracting State, carries on business in the other Contracting State through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the income is paid is effectively connected with such permanent establishment or fixed base.

Article 7or Article 14, as the case may be, shall apply.

ARTICLE 23 Elimination of Double Taxation 1. ( a ) Subject to the provisions of the laws of Ireland, where a resident of Ireland receives income which according to the provisions of this Agreement may be taxed in Russia, the amount of tax on such income paid in Russia shall be deducted from the tax levied on the income of such person in Ireland. Such deduction shall not, however, exceed the amount of the tax calculated in respect of such income in accordance with the laws and rules of Ireland. ( b ) For the purposes of sub-paragraph (a), the amount of tax paid in Russia in respect of a dividend received by a company which is a resident of Ireland from a company which is a resident of Russia shall include the amount of the Russian tax paid on the profits out of which the dividend is paid in proportion to the participation by the Irish company in the Russian company which paid the dividend. 2. ( a ) Subject to the provisions of the laws of Russia, where a resident of Russia receives income which according to the provisions of this Agreement may be taxed in Ireland, the amount of tax on such income paid in Ireland shall be deducted from the tax levied on the income of such person in Russia. Such deduction shall not, however, exceed the amount of the tax calculated in respect of such income in accordance with the laws and rules of Russia. ( b ) For the purposes of sub-paragraph (a), the amount of tax paid in Ireland in respect of a dividend received by a company which is a resident of Russia from a company which is a resident of Ireland shall include the amount of the Irish tax paid on the profits out of which the dividend is paid in proportion to the participation by the Russian company in the Irish company which paid the dividend. ARTICLE 24 Non-discrimination 1. Citizens of a Contracting State or legal entities deriving their status as such from the laws in force in that State or wholly or partly owned by persons who are residents of that State shall not be subjected in the other Contracting State to any taxation or any requirement connected therewith, which is other or more burdensome than the taxation and connected requirements to which citizens and legal entities of that other State in the same circumstances are or may be subjected. This provision shall, notwithstanding the provisions of Article 1, also apply to persons who are not residents of one or both of the Contracting States and, if so permitted by the law of the Contracting State concerned, to stateless persons who are residents of that Contracting State. 2. The taxation on a permanent establishment which a resident of a Contracting State has in the other Contracting State shall not be less favourably levied in that other State than the taxation levied on residents of that other State carrying on similar activities under the same conditions. 3. Nothing contained in this Article shall be interpreted to oblige a Contracting State to give to individuals not resident in that State the right to any of the personal allowances, reliefs and reductions for tax purposes which are granted to individuals who are residents of that State. 4. The provisions of this Article shall apply to the taxes which are the subject of this Agreement. ARTICLE 25 Exchange of Information 1. The competent authorities of the Contracting States shall exchange such information as is necessary for carrying out the provisions of this Agreement or of the domestic laws of the Contracting States concerning taxes covered by the Agreement insofar as the taxation thereunder is not contrary to the Agreement. Any information so exchanged shall be treated as confidential in the same manner as information obtained under the domestic laws of that State and shall be disclosed only to persons or authorities (including courts and administrative bodies) involved in the assessment or collection of, or the enforcement or prosecution in respect of, the taxes covered by the Agreement. Such persons or authorities shall use the information only for such purposes. They may disclose the information in public court proceedings or in judicial decisions. 2. In no case shall the provisions of paragraph 1 of this Article be interpreted so as to impose on a Contracting State the obligation: ( a ) to carry out administrative measures at variance with the laws and administrative practice of that or of the other Contracting State; ( b ) to supply information which is not obtainable under the laws or in the normal course of the administration of that or of the other Contracting State; ( c ) to supply information which would disclose any trade, business, industrial, commercial or professional secret or trade process or information, the disclosure of which would be contrary to public policy. ARTICLE 26 Mutual Agreement Procedure 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Agreement, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, in the case of an individual, to that of the Contracting State of which he is a citizen. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement. 2. The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation which is not in accordance with the provisions of this Agreement. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. 3. The competent authorities of the Contracting States shall endeavour to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of the Agreement. 4. The competent authorities of the Contracting States may communicate with each other directly for the purpose of reaching an agreement in the sense of the preceding paragraphs. ARTICLE 27 Other Tax Privileges Nothing in this Agreement shall affect the tax privileges of persons for whom they are provided under the general rules of international law or under the provisions of special agreements. ARTICLE 28 Entry into Force 1. This Agreement shall be ratified by both Contracting States. 2. This Agreement shall enter into force on the date of the exchange of instruments of ratification and its provisions shall have effect; ( a ) in Ireland: (

1. i)as respects income tax and capital gains tax, for any year of assessment beginning on or after the sixth day of April of the year following the date on which this Agreement enters into force; (
2. ii)as respects corporation tax, for any financial year beginning on or after the first day of January of the year following the year in which this Agreement enters into force; ( b ) in Russia: (
3. i)in respect of taxes withheld at source for income paid or transferred starting from the first day of January of the calendar year, following the year in which the Agreement enters into force; (
4. ii)in respect of other taxes, for taxable periods beginning on or after the first day of January of the calendar year, following the year in which the Agreement enters into force. ARTICLE 29 Termination This Agreement shall remain in force unless terminated by a Contracting State. Either Contracting State may terminate the Agreement at any time after 5 years from the date on which the Agreement enters into force, by giving, through diplomatic channels at least 6 months prior notice of termination in writing. In such event the Agreement is terminated: ( a ) in Ireland; (
5. i)as respects income tax and capital gains tax, for any year of assessment beginning on or after the sixth day of April of the year following the date on which the period specified in the said notice of termination expires; (
6. ii)as respects corporation tax, for any financial year beginning on or after the first day of January of the year following the date on which the period specified in the said notice of termination expires. ( b ) in Russia: (
7. i)in respect of taxes withheld at source for income paid or accrued on or after the first day of January of the year following the expiration of the 6 month period; (
8. ii)in respect of other taxes, for taxable periods beginning on or after the first day of January of the year following the expiration of the six month period. Done at Moscow on 29 April 1994 in duplicate, in the Russian and English languages, both texts being equally authentic. DICK SPRING ANDREI VLADIMIROVICH KOZYREV For the Government of Ireland For the Government of the Russian Federation Excellency, I have the honour to refer to the Agreement between the Government of Ireland and the Government of the Russian Federation for the Avoidance of Double Taxation with respect to Taxes on Income which has been signed today and to make on behalf of the Government of Ireland the following proposals for the purpose of its application. 1. In the case of interest, wages and salaries paid by an enterprise of a Contracting State the capital of which is wholly or partly owned or controlled, directly or indirectly, by residents of the other Contracting State, such interest, wages and salaries shall be deductible in computing the taxable profits of such enterprise. The foregoing sentence shall apply accordingly to interest, wages and salaries when computing the taxable profits of a permanent establishment of an enterprise of a Contracting State. In the event that the Russian law "On taxes on profits of enterprises and organisations" or the Irish Corporation Tax ceases to have effect, such enterprise or permanent establishment will be permitted to continue to compute its tax as specified in this paragraph. 2. Each Contracting State shall endeavour to establish procedures to enable taxpayers to receive income without the imposition of withholding taxes where the Agreement provides for taxation only in the State of residence. Where the Agreement provides for taxation in the State where the income arises, each State shall endeavour to establish procedures to enable taxpayers to receive income after deduction of tax at the rate provided for in the Agreement. Where a claim is made by a taxpayer, tax withheld at source in a Contracting State at the rate provided for under domestic law shall be repaid in a timely manner where that tax is withheld at a rate in excess of that provided for under the terms of the Agreement. If the foregoing proposals are acceptable to the Government of the Russian Federation I have the honour to suggest that the present Note and Your Excellency's reply to that effect shall be regarded as constituting an agreement between the two Governments in this matter which shall enter into force at the same time as the entry into force of the Agreement. I avail myself of this opportunity to renew to Your Excellency the assurance of my highest consideration. Dick Spring T.D. Tánaiste and Minister for Foreign Affairs of Ireland 29 April 1994 Excellency, I have received your Note of 29 April 1994, that states the following: 1. In the case of interest, wages and salaries paid by an enterprise of a Contracting State the capital of which is wholly or partly owned or controlled, directly or indirectly, by residents of the other Contracting State, such interest, wages and salaries shall be deductible in computing the taxable profits of such enterprise. The foregoing sentence shall apply accordingly to interest, wages and salaries when computing the taxable profits of a permanent establishment of an enterprise of a Contracting State. In the event that the Russian law "On taxes on profits of enterprises and organisations" or the Irish Corporation Tax ceases to have effect, such enterprise or permanent establishment will be permitted to continue to compute its tax as specified in this paragraph. 2. Each Contracting State shall endeavour to establish procedures to enable taxpayers to receive income without the imposition of withholding taxes where the Agreement provides for taxation only in the State of residence. Where the Agreement provides for taxation in the State where the income arises, each State shall endeavour to establish procedures to enable taxpayers to receive income after deduction of tax at the rate provided for in the Agreement. Where a claim is made by a taxpayer, tax withheld at source in a Contracting State at the rate provided for under domestic law shall be repaid in a timely manner where that tax is withheld at a rate in excess of that provided for under the terms of the Agreement. The foregoing proposals are acceptable to the Government of the Russian Federation. I have the honour to confirm that Your Excellency's Note and the present reply shall be regarded as constituting an agreement between the two Governments in this matter which shall enter into force at the same time as the entry into force of the Agreement. I avail myself of this opportunity to renew to Your Excellency the assurance of my highest consideration. Andrei Vladimirovich Kozyrev Minister of Foreign Affairs of the Russian Federation 29 April 1994 GIVEN under the Official Seal of the Government, this 13th day of December, 1994. ALBERT REYNOLDS, Taoiseach. EXPLANATORY NOTE. This Order gives the force of law in Ireland to the Agreement with the Russian Federation set out in the Schedule to the Order. The Agreement provides for the allocation of taxing rights between Ireland and Russia and for the granting of relief from double taxation with regard to items of income and capital gains which, under the laws of Ireland and the laws of Russia, may be taxed in both countries. For example, items such as business profits, interest, royalties and gains on movable property not arising through or connected with a permanent establishment in the source country, profits from the operation of ships, aircraft and land transport vehicles in international traffic and payments of pensions and annuities are taxable only in the country of residence of the recipient. On the other hand, remuneration in respect of services rendered to a government of one of the countries is normally taxable only in that country, i.e. the country of source. Where both countries continue to have taxing rights, for example, with regard to business profits arising through a permanent establishment which an enterprise of one country has in the other country or dividends received in one country from the other country, the Agreement provides that the country of residence of the recipient will allow a credit against its own tax for the tax imposed on the same income by the country of source. Thus double taxation is relieved. The Agreement effectively secures that rentals received by an Irish enterprise in respect of the leasing of ships, aircraft, land transport vehicles or containers used in international traffic will be taxable only in Ireland. Capital gains arising from the disposal of immovable property and of shares linked with immovable property may be taxed by the country in which the property is situated. Capital gains arising from the disposal of other property are normally to be taxed only in the country of residence of the taxpayer unless they arise from the disposal of assets of a permanent establishment or fixed base which the taxpayer has in the other country. Double taxation is relieved by the granting of a credit in the country of residence for tax paid in the country where the property is located. A provision in the Agreement preserves the taxation rights of a State in respect of income and capital gains arising from a drilling operation for the exploration or exploitation of natural resources in the territory of that State where such operation is carried on for more than twelve months. In the case of dividends flowing between the two countries the Agreement provides for a withholding tax of 10 per cent. This represents a reduction from the current domestic Russian rate of 15 per cent. Under Irish domestic law no withholding tax will in fact be levied on dividends flowing from Ireland to Russia. Provision is made for safeguarding citizens and enterprises of one country against discriminatory taxation in the other country, for consultation between the competent authorities for the purpose of resolving any difficulties or doubts arising as to the interpretation or application of the Agreement and for the exchange of such information between these authorities as is necessary for carrying out the provisions of the Agreement or of the domestic laws of the Contracting States concerning taxes covered by the Agreement. The Notes exchanged when the Agreement was signed set out agreed proposals in relation to the application of the Agreement. The Notes provide that actual interest, wages and salaries of an enterprise in one country owned or controlled by residents of the other country must be allowed as a deduction when computing the taxable profits of the enterprise. This proposal is based on similar provisions in treaties negotiated by the United States and the United Kingdom with the Russian Federation. The other proposal in the Notes concerns the establishment of procedures to ensure that the treaty rates of withholding tax are applied at source or else taxes applied at rates higher than permitted under the treaty are quickly repaid. The Agreement will become operative— Ireland: (
9. i)as respects income tax and capital gains tax, for any year of assessment beginning on or after the sixth day of April of the year following the date on which the Agreement enters into force; (
10. ii)as respects corporation tax, for any financial year beginning on or after the first day of January of the year following the year in which this Agreement enters into force; Russia: (
11. i)in respect of taxes withheld at source for income paid or transferred starting from the first day of January of the calendar year, following the year in which the Agreement enters into force; (
12. ii)in respect of other taxes, for taxable periods beginning on or after the first day of January of the calendar year, following the year in which the Agreement enters into force. Privacy Statement Accessibility European Legislation Identifier (PDF) Open Data License Ráiteas Príobháideachais Inrochtaineacht Aitheantóir Eorpach Reachtaíochta (ELI) Ceadúnas Sonraí Oscailte Liosta Fianán © Government of Ireland. Oireachtas Copyright Material is reproduced with the permission of the Houses of the Oireachtas © Rialtas na hÉireann. Atáirgtear ábhar faoi Chóipcheart le cead ó Thithe an Oireachtais