Ireland’s extensive list of double taxation treaties with 73 countries

By Andrew Lambe, 13th November 2012 (Updated 14th June 2017)

Ireland is renowned as one of the best countries in the world in which to incorporate a company. One of the most compelling reasons for this is the extensive list of tax treaties that Ireland has in place.

If you are resident in one country and have income and gains from another, you may have to pay tax on the same income in both countries. A double taxation agreement ensures that you only pay tax to one country. The specific agreement will determine which country has the right to collect the tax.

Ireland currently has signed comprehensive double taxation agreements with 73 countries, 72 of which are currently in effect. The agreement between Ireland and Kazakhstan has not yet been brought into effect. The agreements cover direct taxes which in Ireland include income tax, universal social charge, corporation tax and/or capital gains tax.

Ireland currently has a double taxation agreement with the following countries:

 

CountrySigning Date
Albania16/10/2009
Armenia14/07/2011
Australia31/05/1983
Austria*24/05/1966
Bahrain19/06/2009
Belarus03/11/1970
Belgium*24/06/1970
Bosnia-Herzegovina03/11/2009
Botswana10/06/2014
Bulgaria05/10/2000
Canada08/10/2003
Chile02/06/2005
China19/04/2000
Croatia21/06/2002
Cyprus*24/09/1968
Czech Republic14/10/1995
Denmark26/04/1993
Egypt09/04/2012
Estonia16/12/1997
Ethiopia03/11/2014
Finland27/03/1992
France21/03/1968
Georgia20/11/2008
Germany30/03/2011
Greece17/10/1962
Hong Kong22/06/2010
Hungary25/03/1995
Iceland17/12/2003
India16/11/2000
Israel20/11/1995
Italy*11/06/1971
Japan*18/01/1974
Korea (Republic of)18/07/1990
Kuwait23/11/2010
Latvia13/11/1997
Lithuania18/11/1997
Luxembourg*14/01/1972
Macedonia14/04/2008
Malaysia28/11/1998
Malta14/11/2011
Mexico22/10/1998
Moldova28/05/2009
Montenegro17/10/2010
Morocco22/06/2010
Netherlands*11/02/1969
New Zealand19/09/1986
Norway22/11/2000
Pakistan*16/04/1973
Panama28/10/2011
Poland13/10/1995
Portugal01/06/1993
Qatar21/06/2012
Romania21/10/1999
Russia29/04/1994
Saudi Arabia19/10/2011
Serbia23/09/2009
Singapore28/10/2010
Slovak Republic08/06/1999
Slovenia12/03/2002
South Africa07/10/1997
Spain10/02/1994
Sweden08/10/1986
Switzerland*08/11/1966
Thailand24/10/2008
Turkey26/01/2012
UAE -United Arab Emirates01/07/2010
Ukraine19/04/2013
UK- United Kingdom02/06/1976
USA- United States of America28/07/1997
Uzbekistan11/07/2012
Vietnam10/03/1971
Zambia*29/03/1971


*with retroactive effect 

Retroactive tax is one that is passed at one time, but payable back to a time before the tax was passed.

 

My Country is Not on the List

In countries or jurisdictions where Ireland has not signed a double taxation agreement or a double taxation agreement does not cover a particular tax there may be a unilateral relief. As per the Taxes Consolidation Act 1997 (TCA 1997), there is relief against double taxation for some types of income or gains:

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

Protocols to the existing agreements with Belgium, Denmark and Luxembourg were signed on 14 April, 22 July and 27 May 2014 respectively. The legal procedures to bring these protocols into force are now being followed.

 

Double Taxation Treaties and Amendments in Progress

  • Treaty with Kazakhstan was signed on 26 April 2017. Procedures to put the treaty into practice are in progress.
  •  Treaty to replace the existing agreements with Pakistan were signed 16 April 2015 and was put into force 1 January 2017.
  •  Treaty with Botswana was signed 10 June 2014 and was put into force 1 January 2017.
  • Treaty with Ethiopia was signed on 3 November 2014 and was put into force 1 January
  • Protocol with Belgium has not yet been put into force. Ratification procedures to the existing agreement are in progress.
  • Negotiations with Mexico on a Protocol to the existing agreement have concluded.
  • Negotiations for Double Taxation agreements have concluded with Azerbaijan, Ghana, Oman, Turkmenistan, and Uruguay.

 

For more information on the above including the benefits of registering a company in Ireland please don’t hesitate to contact us at Company Bureau.

 

Disclaimer: The above article does not constitute tax advice, therefore, paid professional taxation advice should be sought before considering any of the structures mentioned above. We are not responsible for any possible incorrect information contained in the above which was sourced from 3rd parties including the Irish Revenue Commissioners.

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