Ireland’s extensive list of double taxation treaties

By Andrew Lambe, 13th November 2012 (Updated 8th October 2021)

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 a 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 74 countries, 73 of which are currently in effect. There is an outstanding agreement between Ireland and Ghana has not yet been brought into effect. These double taxation 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:

*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

• A new tax treaty with Ghana was signed on 7th February 2018. Procedures to put the treaty into practice are in progress.
• Treaty to replace the existing agreements with Pakistan were signed 16th April 2015 and was put into force 1st January 2017.
• Treaty with Botswana was signed 10th June 2014 and was put into force 1st January 2017.
• Treaty between Ireland and the Netherlands entered into force on 29^th February 2020. The provision of this treaty entered into effect on 1^st January 2021.
• The current protocol to the existing DTA & Amending Protocols between Ireland and Switzerland entered into force on 21^st October 202 and, its provision entered effect on 1^st January 2021.
• Ireland and Germany signed a protocol on 19^th January 2021, to amend the existing Double Tax Treaty & Amending Protocol between the two countries.
• Protocol with Belgium has not yet been put into force. Ratification procedures to the existing agreement are in progress.
• Negotiations regarding Double Tax Treaties have concluded with Kenya, Kosovo, Oman & Uruguay and the new agreements are expected to be signed shortly.
• Negotiations have concluded on protocols to exiting tax treaties with Guernsey, Isle of Man & Mexico.
• Negotiations for Double Taxation agreements have concluded with Azerbaijan, 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.