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HMRC internal manual

Double Taxation Relief Manual

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HM Revenue & Customs
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Double Taxation Relief Manual: Guidance by country: Ireland: Charities: superannuation funds

Article 11(2) and Article 14A(1) of the agreement, provide that dividends, income from property and capital gains from the disposal of immovable property and related movable property are to be exempt from tax in the country of source where the income or gain is derived by a charity or superannuation scheme which is a resident of the other country and is exempt from tax in that country in respect of the income or gain. The responsibilities of tax offices in this connection are confined

a) to giving effect to any exemption from United Kingdom tax authorised by the Centre for Non-Residents, Nottingham;

b) in regard to a claim by a United Kingdom superannuation scheme, to certifying, that the claimant is resident in the United Kingdom for the purposes of tax but wholly or partially exempt as a superannuation scheme, to indicating the statutes under which the superannuation scheme is wholly or partially exempt from tax and to stating (if known) the percentage of any partial exemption for the year in question;

c) to referring any request for certification received from a United Kingdom charity to Charities (Charity Title), or Charities (Scotland) for Scottish cases.