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HMRC internal manual

International Manual

DT Agreements: Ireland - Income from a UK source paid to a resident of Ireland

Limitation of relief - remittance condition

Where an individual’s liability to tax in Ireland is calculated by reference tothe amount of that person’s income that is remitted to or received in Ireland, thenthe amount of relief from UK tax that is available is limited to that relating to theamount remitted to or received in Ireland.