Tax Treaties

Ireland has signed comprehensive double taxation agreements with 68 countries, of which 61 are in effect.

The agreements cover direct taxes, which in the case of Ireland are income tax, corporation tax and capital gains tax.

The countries that Ireland has a double taxation agreement are:

  • Albania
  • Armenia (effective 1st January 2013)
  • Australia  
  • Austria
  • Bahrain  
  • Belarus  
  • Belgium
  • Bosnia Herzegovina  
  • Bulgaria
  • Canada  
  • Chile  China  
  • Croatia  
  • Cyprus
  • Czech Republic
  • Denmark
  • Egypt (pending)  
  • Estonia
  • Finland
  • France
  • Georgia  
  • Germany
  • Greece
  • Hong Kong  
  • Hungary
  • Iceland  
  • India  
  • Israel  
  • Italy
  • Japan  
  • Republic of Korea  
  • Latvia
  • Lithuania
  • Luxembourg
  • Kuwait  
  • Macedonia  
  • Malaysia  
  • Malta
  • Mexico  
  • Moldova  
  • Montenegro
  • Morocco  
  • The Netherlands
  • New Zealand  
  • Norway  P
  • akistan  
  • Panama  
  • Poland
  • Portugal
  • Qatar  
  • Romania
  • Russia  
  • Saudi Arabia  
  • Serbia  
  • Singapore  
  • Slovakia
  • South Africa  
  • Spain
  • Sweden
  • Switzerland  
  • Turkey
  • United Arab Emirates
  • United Kingdom
  • United States of America  
  • Uzbekistan  
  • Vietnam  
  • Zambia

New agreements with Albania, Bosnia & Herzegovina, Hong Kong and Montenegro are effective from 1 January 2012. A new agreement with Armenia will be effective from 1 January 2013. New agreements have been signed with Egypt on 9 April 2012, Qatar on 21 June 2012 and Uzbekistan on 11 July 2012. The legal procedures to bring these agreements into force are now being followed.

A new agreement which will replace the existing agreement with Germany was signed on 30 March 2011. This agreement came into force on 28 November 2012 and is effective from 1 January 2013. Ireland has completed the ratification procedures to bring the new agreements with Kuwait, Panama and Saudi Arabia into force. When ratification procedures are also completed by these countries, the agreements will enter into force. A protocol to the existing agreement with South Africa came into force on the 10 February 2012 and is effective from 1 April 2012 for Articles III and VI of the Protocol and from 1 January 2013 for the other articles. Ireland has completed the ratification procedures to bring the protocol to the existing agreement with Malaysia into force. When ratification procedures are also completed by Malaysia, the protocol will enter into force. A protocol to the existing agreement with Switzerland was signed on 26 January 2012. The legal procedures to bring this protocol into force are now being followed. Negotiations for new agreements with Thailand and Ukraine have been concluded and are expected to be signed shortly. Negotiations on Protocols to the existing agreements with Belgium and Luxembourg have also been concluded.

Negotiations for new agreements with the following countries are at various stages: Azerbaijan and Tunisia. Negotiations are ongoing for the revision of the existing agreements with Pakistan and with the Netherlands. It is also planned to initiate negotiations for new agreements with other countries in the course of 2012.   Where a double taxation agreement does not exist with a particular country there are provisions in the Irish Taxes Consolidation Acts (TCA) 1997 which allow unilateral relief against double taxation in respect of certain types of income. The principal provisions granting unilateral relief are as follows: dividends from foreign subsidiaries: credit for withholding tax on dividend payments and for foreign tax paid on the underlying profits out of which the dividends were paid (paragraph 9A and B of Schedule 24 TCA 1997) pooling and carry-forward of excess foreign tax credits (paragraph 9E of Schedule 24 TCA 1997) credit for foreign tax on dividends paid by a foreign company that is a member of a group that paid tax on a consolidated basis (paragraph 9G of Schedule 24 TCA 1997)

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