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HMRC internal manual

International Manual

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

Other income paid to a resident of Ireland

Article 20: ‘Income not expressly mentioned’ provides for full relief from UKtax for ‘other income’, except for:

  • income paid out of trusts, and
  • income paid out of estates of deceased persons in administration

for both of which there is no relief.

Article 20(3) disallows relief if the motive for the relevant transaction was to takeadvantage of the convention. Please refer any queries/questions about this to TechnicalAdvice group.