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HMRC internal manual

International Manual

HM Revenue & Customs
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DT Agreements: Ireland - Income from a UK source paid to a resident of Ireland

UK interest paid to a resident of Ireland

Article 12 of the convention provides for full relief from UK income tax in respect ofinterest paid to a resident of Ireland who is the beneficial owner of the interest.

Article 12(5) disallows treaty benefits if the motive for the loan in question was to takeadvantage of the convention. Please refer any queries or questions about this to TechnicalAdvice group.