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HMRC internal manual

Double Taxation Relief Manual

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Double Taxation Relief Manual: Guidance by country: Ireland: Agreements

The comprehensive agreement (SI1976/2151) and protocol (SI1976/2152) entered into force on 23 December 1976 and has effect

a) In the United Kingdom for

i) Income Tax (other than Income Tax on salaries, wages, remuneration and governmental pensions) from 1976-77,  


ii) Income Tax on salaries, wages, remuneration and governmental pensions from 1977-78,  


iii) Capital Gains Tax from 1976-77,  


iv) Corporation Tax from 6 April 1976,  


v) Petroleum Revenue Tax from 1 January 1976.  

b) In Ireland for:

i) Income Tax (other than Income Tax on salaries, wages, remuneration and governmental pensions) from 1976-77,  


ii) Income Tax on salaries, wages, remuneration and governmental pensions from 1977-78,  


iii) Capital Gains Tax from 1976-77,  


iv) Corporation Tax from 1 April 1974.  


An amending agreement (SI1995/764) adding provisions on pension scheme contributions (see DT9892) had effect in the United Kingdom from 1 April 1994 in respect of Corporation Tax and 6 April 1994 in respect of Income Tax.  


A further amending agreement (SI1998/3151) replacing the dividend, capital gains, government service and other income articles and revising the permanent establishment and interest articles had effect in the United Kingdom from 1 April 1999 in respect of Corporation Tax and 6 April 1999 in respect of Income Tax.  

If using the HMRC Intranet, the agreements can be viewed through the “New treaties/protocols in force” link on the sidebar. On the HMRC web-site, searching for “Treaties in force Ireland” will provide a link to the treaty.