when we once lived
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 8, Double Taxation Treaty, Ireland/Austria, 1967 *
Origin: Direct Taxes Interpretation & International
File ref:521/2005