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S.I. No. 323/1995 - Double Taxation Relief (Taxes on Income) (State of Israel) Order, 1995.

S.I. No. 323/1995 - Double Taxation Relief (Taxes on Income) (State of Israel) Order, 1995. Skip to content Disclaimer Feedback Helpdesk Gaeilge Léim go dtí an t-ábhar Séanadh Aiseolas Deasc chabhrach

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, nor subject the company's undistributed profits to a tax on the company's undistributed profits, 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 may be taxed in that other State.
  3. However, such interest may also be taxed in the Contracting State in which it arises and according to the laws of that State, but if the recipient is the beneficial owner of the interest the tax so charged shall not exceed 10 per cent of the gross amount of the interest. The competent authorities of the Contracting State shall by mutual consent settle the mode of application of this limitation.
  4. Notwithstanding the provisions of paragraph 2, any such interest as is mentioned in paragraph 1 may also be taxed in the Contracting State in which it arises and according to the laws of that State, but if the recipient is the beneficial owner of the interest the tax so charged shall not exceed 5 per cent of the gross amount of the interest where such interest is paid: ( a ) in connection with the sale on credit of any industrial, commercial or scientific equipment, ( b ) in connection with the sale on credit of any merchandise by one enterprise to another enterprise, or ( c ) on any loan of whatever kind granted by a bank.
  5. The term "interest" as used in this Article means income from debt-claims of every kind, whether or not secured by mortgage and whether or not carrying a right to participate in the debtor's profits, and in particular, income from government securities and income from bonds or debentures, including premiums and prizes attaching to bonds or debentures, but does not include any income which is treated as a dividend under Article
  6. Penalty charges for late payment shall not be regarded as interest for the purpose of this Article.
  7. The provisions of paragraphs 1, 2 and 3 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 debt-claim in respect of which the interest is paid is effectively connected with such permanent establishment or fixed base.

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

  1. 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 Convention.
  2. Interest shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority 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 borne 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.
  3. The provisions of paragraphs 2 and 3 shall not apply if the debt-claim in respect of which the interest is paid was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. ARTICLE 12 Royalties
  4. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State.
  5. However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties, the tax so charged shall not exceed 10 per cent of the gross amount of the royalties. The competent authorities of the Contracting States shall by mutual agreement settle the mode of application of this limitation.
  6. 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 cinematograph films, video recordings, and films or tapes for radio or television broadcasting), any patent, trade mark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience.
  7. The provisions of paragraphs 1 and 2 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.

  1. Royalties shall be deemed to arise in a Contracting State where the payer is that State itself, a political subdivision, a local authority 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 the royalties are borne by that permanent establishment or fixed base, then the royalties shall be deemed to arise in the Contracting 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 royalties, having regard to the use, right or information for which they are 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 Convention.
  3. The provisions of paragraph 2 shall not apply if the right or property giving rise to the royalties was created or assigned mainly for the purpose of taking advantage of this Article and not for bona fide commercial reasons. ARTICLE 13 Capital Gains
  4. Gains derived by a resident of a Contracting State from the alienation of immovable property referred to in Article 6 and situated in the other Contracting State may be taxed in that other State.
  5. Gains from the alienation of movable property forming part of the business property of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State or of movable property pertaining to a fixed base available to a resident of a Contracting State in the other Contracting State for the purpose of performing independent personal services, including such gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such fixed base, may be taxed in that other Contracting State.
  6. Gains derived by an enterprise of a Contracting State from the alienation of ships or aircraft operated in international traffic, or movable property pertaining to the operation of such ships or aircraft, shall be taxable only in that Contracting State.
  7. Gains derived by a resident of a Contracting State from the sale, exchange or other disposition, directly or indirectly, of shares or similar rights in a company which is a resident of the other Contracting State, may be taxed in that other State, but only if the resident of the first-mentioned State owned either directly or indirectly at any time within the two-year period preceding such sale, exchange or other disposition, shares giving the right to 10 per cent or more of the voting power in the company. For the purposes of this paragraph indirect ownership shall be deemed to include, but not be limited to, ownership by a related person.
  8. Gains from the alienation of shares or similar rights in a company, 50 per cent or more of the assets of which consist directly or indirectly of immovable property situated in a Contracting State, may be taxed in that State. Gains from the alienation of an interest in a partnership, trust or estate, the property of which consists principally of immovable property situated in a Contracting State, may be taxed in that State.
  9. Gains from the alienation of any property other than that referred to in paragraphs 1, 2, 3, 4 and 5 shall be taxable only in the Contracting State of which the alienator is a resident. ARTICLE 14 Independent Personal Services
  10. Income derived by a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that State. However, such income may also be taxed in the other Contracting State if: ( a ) the resident has a fixed base regularly available to him in that other State for the purpose of performing his activities; or ( b ) the resident, being an individual, is present in the other State for a period or periods exceeding in the aggregate 183 days in any twelve month period commencing or ending in the fiscal year concerned of that other State; but only so much thereof as is attributable to services performed in that other State.
  11. The term "professional 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 Dependent Personal Services
  12. Subject to the provisions of Articles 16, 18, 19 and 20, 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.
  13. Notwithstanding the provisions of paragraph 1, 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: ( a ) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in any twelve month period commencing or ending in the fiscal year concerned, and ( b ) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State, and ( c ) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
  14. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State, may be taxed in that State. 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 any similar organ of a company which is a resident of the other Contracting State may be taxed in that other State. ARTICLE 17 Artistes and Athletes
  15. Notwithstanding the provisions of Articles 14 and 15, 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 State.
  16. Where income in respect of personal activities exercised by an entertainer or an 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, be taxed in the Contracting State in which the activities of the entertainer or athlete are exercised. ARTICLE 18 Pensions and Annuities
  17. Subject to the provisions of paragraph 2 of Article 19, pensions and other similar remuneration paid to a resident of a Contracting State in consideration of past employment and any retirement annuity paid to such a resident shall be taxable only in that State.
  18. 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 Government Service
  19. ( a ) Remuneration, other than a pension, paid by a Contracting State or a political subdivision or a local authority thereof to an individual in respect of services rendered to that State or subdivision or authority shall be taxable only in that State. ( b ) 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: (i) is a national of that State; or (ii) did not become a resident of that State solely for the purpose of rendering the services.
  20. ( a ) Any pension paid by, or out of funds created by, a Contracting State or a political subdivision or a local authority thereof to an individual in respect of services rendered to that State or subdivision or authority shall be taxable only in that State. ( b ) However, such pension shall be taxable only in the other Contracting State if the individual is a resident of, and a national of, that State.
  21. The provisions of Articles 15, 16 and 18 shall apply to remuneration and pensions in respect of services rendered in connection with a business carried on by a Contracting State or a political subdivision or a local authority thereof. ARTICLE 20 Professors and Teachers A professor or teacher who visits one of the Contracting States for the principal purpose of teaching or carrying out advanced study or research at any educational institution not operated for profit in that Contracting State and who was immediately before that visit a resident of the other Contracting State shall be exempt from tax in the first-mentioned Contracting State for a period of two years from the date of his arrival therein. ARTICLE 21 Students and Business Apprentices
  22. Payments which a student or a business apprentice who is or was immediately before visiting a Contracting State a resident of the other Contracting State and who is present in the first-mentioned Contracting State solely for the purpose of his education or training receives for the purpose of his maintenance, education or training shall not be taxed in that State, provided that such payments arise from sources outside that State.
  23. In respect of grants, scholarships and remuneration from employment not covered by paragraph 1, a student or business apprentice described in paragraph 1 shall, in addition, be entitled during such education or training to the same exemptions, reliefs or reductions in respect of taxes as are available to residents of the Contracting State which he is visiting. ARTICLE 22 Other Income
  24. Items of income of a resident of a Contracting State, wherever arising, not dealt with in the foregoing Articles of this Convention shall be taxable only in that State.
  25. The provisions of paragraph 1 shall not apply to income, other than income from immovable property as defined in paragraph 2 of Article 6, if the beneficial owner of such 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 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. Subject to the laws of Israel from time to time in force regarding the allowance as a credit against Israeli tax of tax paid in any country other than Israel, Irish tax paid in respect of income derived from Ireland shall be allowed as a credit against Israeli tax payable in respect of that income. The credit shall not, however, exceed that portion of Israeli tax which the income from sources within Ireland bears to the entire income subject to Israeli tax. In the case of a dividend paid by a company which is a resident of Ireland to a company which is a resident of Israel and which controls directly or indirectly 10 per cent or more of the voting power in the company paying the dividend, the credit shall take into account (in addition to any Irish tax for which credit may be allowed under the provisions of the first sentence of this paragraph) Irish tax payable by the company in respect of the profits out of which such dividend is paid. 2. Subject to the provisions of the laws of Ireland regarding the allowance as a credit against Irish tax of tax payable in a territory outside Ireland (which shall not affect the general principal hereof): (

  1. a)Israeli tax payable under the laws of Israel and in accordance with this Convention, whether directly or by deduction, on profits, income or gains from sources within Israel (excluding in the case of a dividend tax payable in respect of the profits out of which the dividend is paid) shall be allowed as a credit against any Irish tax computed by reference to the same profits, income or gains by reference to which Israeli tax is computed. (
  2. b)In the case of a dividend paid by a company which is a resident of Israel to a company which is a resident of Ireland and which controls directly or indirectly 10 per cent or more of the voting power in the company paying the dividend, the credit shall take into account (in addition to any Israeli tax for which credit may be allowed under the provisions of subparagraph (
  3. a)of this paragraph) Israeli tax payable by the company in respect of the profits out of which such dividend is paid. 3. For the purposes of this Article, profits, income and gains derived by a resident of a Contracting State which may be taxed in the other Contracting State in accordance with this Convention shall be deemed to be derived from sources in that other State. ARTICLE 24 Non-Discrimination 1. Nationals of a Contracting 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 nationals 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. 2. The taxation of a permanent establishment which an enterprise 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 enterprises of that other State carrying on the same activities. This provision shall not be construed as obliging a Contracting State to grant to residents of the other Contracting State any personal allowances, reliefs and reductions for taxation purposes on account of civil status or family responsibilities which it grants to its own residents. 3. Except where the provisions of paragraph 1 of Article 9, paragraph 6 of Article 11, or paragraph 6 of Article 12, apply, interest (other than interest treated as a dividend), royalties and other disbursements paid by an enterprise of a Contracting State to a resident of the other Contracting State shall, for the purpose of determining the taxable profits of such enterprise, be deductible under the same conditions as if they had been paid to a resident of the first-mentioned State. 4. An enterprise of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the first-mentioned State are or may be subjected. 5. Nothing in this Article shall be construed as preventing Israel from imposing income tax according to its laws, in addition to the tax imposed upon the profits of a company resident in Ireland, on the amount of the remittance from Israel of profits made by a permanent establishment of such Irish company situated in Israel at a rate not exceeding the rate applicable to dividends as specified in paragraph 1 of Article 10. 6. Payments made by an individual who is a resident of a Contracting State to a pension scheme established in the other Contracting State may be relieved from tax in the first-mentioned State; in such case relief from tax shall be given in the same way and subject to the same conditions and limitations as if the pension scheme was recognised for tax purposes by the first-mentioned State, and as if the individual was making the contributions to such a pension scheme in that State, provided that: (
  4. a)the pension scheme is accepted by the competent authority of that State as corresponding to a pension scheme recognised for tax purposes by that State; (
  5. b)the individual was a resident of, and was contributing for a period in excess of two years to the pension scheme in, the other Contracting State before he became a resident of the first-mentioned State; and (
  6. c)for the period during which the individual is entitled to relief under this paragraph for contributions to the pension scheme in the other Contracting State, such individual shall be precluded from enjoying any tax relief granted by the other Contracting State in respect of the same contributions. ARTICLE 25 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 Convention, 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, if his case comes under paragraph 1 of Article 24, to that of the Contracting State of which he is a national. 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 Convention. 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 Convention. 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 Convention. In particular, they may agree: (
  7. a)to the same attribution of profits of an enterprise of a Contracting State and its permanent establishment situated in the other Contracting State; (
  8. b)to the same allocation of income between a resident of a Contracting State and any associated or related person; or (
  9. c)to the same classification of particular items of income. They may also consult together for the elimination of double taxation in cases not provided for in the Convention. 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. When it seems advisable in order to reach agreement to have an oral exchange of opinions, such exchange may take place through a commission consisting of representatives of the competent authorities of the Contracting States. 5. If any difficulty or doubt arising as to the interpretation or application of this Convention cannot be resolved by the competent authorities pursuant to the previous paragraphs of this Article, the case may, if both competent authorities and the taxpayer agree, be submitted for arbitration, provided that the taxpayer agrees in writing to be bound by the decision of the arbitration board. The decision of the arbitration board in a particular case shall be binding on both Contracting States with respect to that case. The procedures shall be established between the Contracting States by notes to be exchanged through diplomatic channels. The provisions of this paragraph shall have effect when the Contracting States have so agreed through the exchange of diplomatic notes. ARTICLE 26 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 Convention or of the domestic laws of the Contracting States concerning taxes covered by the Convention insofar as the taxation thereunder is not contrary to the Convention. The exchange of information is not restricted by Article 1. Any information received by a Contracting State shall be treated as secret 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, the enforcement or prosecution in respect of, or the determination of appeals in relation to, the taxes covered by the Convention. 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 be construed so as to impose on a Contracting State the obligation: (
  10. a)to carry out administrative measures at variance with the laws and administrative practice of that or the other Contracting State; (
  11. 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; (
  12. 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 (ordre public). ARTICLE 27 Diplomatic Agents and Consular Officers Nothing in this Convention shall affect the fiscal privileges of diplomatic agents or consular officers under the general rules of international law or under the provisions of special agreements. ARTICLE 28 Entry into Force 1. The Contracting States shall notify each other that the constitutional requirements for the entry into force of this Convention have been complied with. 2. This Convention shall enter into force on the date of the later of the notifications referred to in paragraph 1 and its provisions shall apply: (
  13. a)In Israel: (
  14. i)in respect of taxes withheld at source, to amounts of income derived on or after 1 January 1996; (
  15. ii)in respect of other taxes on income, to such taxes chargeable for any taxable year beginning on or after 1 January 1996. (
  16. b)In Ireland: (
  17. i)as respects income tax and capital gains tax, for any year of assessment beginning on or after 6 April 1996; (
  18. ii)as respects corporation tax, for any financial year beginning on or after 1 January 1996. ARTICLE 29 Termination This Convention shall remain in force until terminated by one of the Contracting States. Either Contracting State may terminate the Convention, through diplomatic channels, by giving notice of termination at least six months before the end of any calendar year following after the period of five years from the date on which the Convention enters into force. In such event the Convention shall cease to have effect: (
  19. a)In Israel: (
  20. i)in respect of taxes withheld at source, to amounts of income derived on or after 1 January in the calendar year next following the year in which the notice is given; (
  21. ii)in respect of other taxes on income, to such taxes chargeable for any taxable year beginning on or after 1 January in the calendar year next following the year in which the notice is given. (
  22. b)In Ireland: (
  23. i)as respects income tax and capital gains tax, for any year of assessment beginning on or after the sixth day of April in the year next following the date on which the period specified in the said notice of termination expires; (
  24. ii)as respects corporation tax, for any financial year beginning on or after the first day of January next following the date on which the period specified in the said notice of termination expires. In witness whereof the undersigned, duly authorised thereto, have signed this Convention. Done at Dublin on 20th day of November, 1995 corresponding to 27 Cheshvan 5756, in duplicate in the English and Hebrew languages, both texts being equally authentic. RUAIRI QUINN For Ireland ZVI GABAY For the State of Israel GIVEN under the Official Seal of the Government, this 5th day of December, 1995. JOHN BRUTON, Taoiseach. EXPLANATORY NOTE. This Order gives the force of law to the Convention with Israel which is set out in the Schedule. The effect of the Convention is summarised as follows. This Convention with Israel, which was signed in Dublin on 20th November, 1995, is comprehensive in scope and is based on the OECD Model Convention. It provides, with regard to income (which includes capital gains) which under the laws of Ireland and the laws of Israel may be taxed in both countries, for the allocation of taxing rights between the two countries and for the granting of relief from double taxation if under the Convention items of income continue to be taxable in both countries. For example, items such as business profits and gains on movable property (provided that they do not arise through or are not connected with a permanent establishment in the source state), profits from the operation of ships or aircraft in international traffic and non-government pensions, are taxable only in the state of residence of the recipient. 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 state has in the other state, or dividends, interest or royalties received in one state from the other state, the Convention provides that the state of residence of the recipient will allow a credit against its own tax for the tax imposed on the same income by the state of source. Thus double taxation is relieved. Capital gains arising from the disposal of immovable property, or of shares in a company or an interest in a partnership, trust or estate, the majority or principal part of the assets of which consist of immovable property, may be taxed by the state in which the property is situated. Other gains, including gains arising from the disposal of ships or aircraft operated in international traffic, are normally taxable only in the state of residence of the taxpayer, unless they arise from the disposal of assets of a permanent establishment or a fixed base, or from shares in a company in the other state in which the alienator has held 10 per cent or more of the voting power at any time in the previous two years; if so, the gains may be taxed in that other state. The Convention preserves the taxation rights of a state in respect of income and capital gains arising from the exploration or exploitation of natural resources in its territory. The Convention also preserves a state's taxing rights in respect of income arising from the provision in that state of services for a period exceeding six months ending in the fiscal year concerned by an enterprise of the other Contracting State. In the case of dividends, interests and royalties flowing between the two states, the Convention provides for a withholding tax of 10 per cent of the gross amount. Except where the shareholder is entitled to a refund of the Irish tax credit attaching to the dividend, no withholding tax is imposed in Ireland under Irish domestic law. The Convention also contains provisions for safeguarding citizens and enterprises of one state against discriminatory taxation in the other, for consultation between the competent authorities in both states for the purpose of resolving any difficulties or doubts arising as to the interpretation or application of the Convention and for the exchange of information between these authorities as is necessary for carrying out the provisions of the Convention or of the domestic laws of the Contracting States concerning the taxes covered by the Convention. Following ratification of the Convention and its being given force in law, it will become operative in both States for the tax periods beginning in 1996. 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

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