Patent royalty - residence
09/08/1991
Query
Interaction of Ireland / UK Double Taxation convention and section 234
Decision
Where a person is a resident of Ireland and not a resident of the UK in accordance with the Irl/UK Double Taxation convention, that person is a resident of Ireland for the purposes of section 234. See also prec. id. 981 of 17 August 2004.
Income Tax
Section 234, Taxes Consolidation Act, 1997
Origin: RLS Division
File ref:IT912011