DT Agreements: Ireland - Income from a UK source paid to a resident of Ireland
UK dividends paid to a resident of Ireland - portfolio investor
The convention as amended makes no provision for payment of tax credit to portfolioinvestors in respect of UK dividends paid on or after 6 April 1999. See INTM343520 for a definition of the term portfolioinvestor.
In respect of UK dividends paid before 6 April 1999, the convention provides for paymentof the excess of UK tax after retention of 15% of the aggregate (of net UK dividend plustax credit) to the beneficial owner of the dividend who is a resident of Ireland.
And also in respect of dividends paid before 6 April 1999, the convention provides forpayment of the full amount of tax credit to a claimant who qualifies as eitherexempt approved or 100% exempt under the (Irish) TaxesConsolidation Act 1997. You will find more information on such bodies at INTM353595.