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HMRC internal manual

Double Taxation Relief Manual

From
HM Revenue & Customs
Updated
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Double Taxation Relief Manual: Guidance by country: Ireland: Source of income

For the purposes of the credit Article (Elimination of double taxation), profits, income and capital gains owned by a resident of one country which may be taxed in the other country in accordance with the agreement are deemed to have their source in that other country (Article 21(3)).