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HMRC internal manual

International Manual

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

Rent paid to a resident of Ireland

Article 14A of the convention (uniquely) provides for full relief in respect of rentpaid to qualifying claimants resident in Ireland.

Only a charity, superannuation scheme, or the pension business of an insurance company canqualify, provided that the Revenue Commissioners of Ireland certify that it satisfies therelevant conditions of the (Irish) Taxes Consolidation Act 1997 to be exempt from incomeand capital gains tax in Ireland.

Acceptable forms of the resulting certification are given at INTM353595.

You will usually be able to authorise relief at source for bodies which are entirelyexempt from Irish tax, but not for the pensions business of an Irishinsurance company.

It will usually not be possible to obtain certification of the proportion of thecompany’s business which is exempt from Irish tax until the end of the tax year. Sothe insurance company will need to join the Non-resident Landlords Scheme (NRLS), and anyrelief due by way of repayment can be offset against the company’s liability to UKincome tax under the NRLS.

If an Irish insurance company applies for relief at source in respect of its pensionbusiness, please consult Technical Advice Group.

See INTM353595 about partially exempt Irish bodies, and INTM370000 about the NRLS.