Artists exemption/patent royalty - residence
17/08/2004
Query
Interaction of Double Taxation Conventions and sections 195 and 234
Decision
Where a person is a resident of Ireland and not a resident of another state in accordance with a Double Taxation Convention between Ireland and that other state, that person is resident in the State and not resident elsewhere for the purpose of section 195 or 234. This effectively extends the scope of precedent 526 of 9 August, 1991.
Income Tax
Section 195 & 234, Taxes Consolidation Act, 1997
Origin: Direct Taxes Interpretation & International
File ref:CRMS: 3985/03