Double Taxation Treaties


Unilateral relief

Where Ireland does not have a DTA with a particular country or jurisdiction or a DTA does not cover a particular tax, the Taxes Consolidation Act 1997 (TCA 1997) provides unilateral relief against double taxation in respect of certain types of income and gains:

  • dividends from foreign subsidiaries
  • foreign branch profits
  • foreign interest and royalties
  • leasing income
  • capital gains on foreign assets.

Paragraphs 9A - 9H of Schedule 24 contain the principal provisions of the TCA 1997 dealing with unilateral relief.

Additional reliefs

There are also reliefs under the following Directives:

  • EU "Parent-Subsidiaries Directive" (90/435/EEC) (section 831 TCA 1997).
  • EU "Interest and Royalties Directive" (2003/49/EC) (section 267G-L TCA 1997).
  • "EU Mergers Directive" (90/434/EEC) (sections 630-638 TCA 1997).

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