Claiming a repayment of dividend withholding tax under the terms of these treaties

30/11/2003

Query

Tax credits for dividends were abolished on 6th April 1999 and references to tax credits in these treaties are now obsolete.

Decision

A dividend withholding tax no longer applies in these cases and a full exemption from this should be granted where the other conditions of the relevant Dividend Article are met.

Dividend Withholding Tax

Article 11, Double Taxation Treaty, Ireland/Australia, 1983

Origin: Direct Taxes Interpretation & International

File ref:521/2005


30/11/2003

Query

Tax credits for dividends were abolished on 6th April 1999 and references to tax credits in these treaties are now obsolete.

Decision

A dividend withholding tax no longer applies in these cases and a full exemption from this should be granted where the other conditions of the relevant Dividend Article are met.

Dividend Withholding Tax

Article 11, Double Taxation Treaty, Ireland/Sweden, 1988 *

Origin: Direct Taxes Interpretation & International

File ref:521/2005


30/11/2003

Query

Tax credits for dividends were abolished on 6th April 1999 and references to tax credits in these treaties are now obsolete.

Decision

A dividend withholding tax no longer applies in these cases and a full exemption from this should be granted where the other conditions of the relevant Dividend Article are met.

Dividend Withholding Tax

Article 9, Double Taxation Treaty, Ireland/Switzerland, 1967 *

Origin: Direct Taxes Interpretation & International

File ref:521/2005


30/11/2003

Query

Tax credits for dividends were abolished on 6th April 1999 and references to tax credits in these treaties are now obsolete.

Decision

A dividend withholding tax no longer applies in these cases and a full exemption from this should be granted where the other conditions of the relevant Dividend Article are met.

Dividend Withholding Tax

Article 10, Double Taxation Treaty, Ireland/Spain, 1994

Origin: Direct Taxes Interpretation & International

File ref:521/2005


30/11/2003

Query

Tax credits for dividends were abolished on 6th April 1999 and references to tax credits in these treaties are now obsolete.

Decision

A dividend withholding tax no longer applies in these cases and a full exemption from this should be granted where the other conditions of the relevant Dividend Article are met.

Dividend Withholding Tax

Article 12, Double Taxation Treaty, Ireland/New Zealand, 1988

Origin: Direct Taxes Interpretation & International

File ref:521/2005


30/11/2003

Query

Tax credits for dividends were abolished on 6th April 1999 and references to tax credits in these treaties are now obsolete.

Decision

A dividend withholding tax no longer applies in these cases and a full exemption from this should be granted where the other conditions of the relevant Dividend Article are met.

Dividend Withholding Tax

Article 10, Double Taxation Treaty, Ireland/Korea, 1991

Origin: Direct Taxes Interpretation & International

File ref:521/2005


30/11/2003

Query

Tax credits for dividends were abolished on 6th April 1999 and references to tax credits in these treaties are now obsolete.

Decision

A dividend withholding tax no longer applies in these cases and a full exemption from this should be granted where the other conditions of the relevant Dividend Article are met.

Dividend Withholding Tax

Article 10, Double Taxation Treaty, Ireland/Denmark, 1993

Origin: Direct Taxes Interpretation & International

File ref:521/2005


30/11/2003

Query

Tax credits for dividends were abolished on 6th April 1999 and references to tax credits in these treaties are now obsolete.

Decision

A dividend withholding tax no longer applies in these cases and a full exemption from this should be granted where the other conditions of the relevant Dividend Article are met.

Dividend Withholding Tax

Article 11, Double Taxation Treaty, Ireland/Finland, 1993

Origin: Direct Taxes Interpretation & International

File ref:521/2005


30/11/2003

Query

Tax credits for dividends were abolished on 6th April 1999 and references to tax credits in these treaties are now obsolete.

Decision

A dividend withholding tax no longer applies in these cases and a full exemption from this should be granted where the other conditions of the relevant Dividend Article are met.

Dividend Withholding Tax

Article 10, Double Taxation Treaty, Ireland/Israel, 1995

Origin: Direct Taxes Interpretation & International

File ref:521/2005




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