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Ireland Ratifies Double Tax Agreements With Malta And Macedonia,
by Jason Gorringe, Tax-News.com, London
Thursday, February 05, 2009
The Irish Revenue has announced the ratification of conventions with Macedonia
and Malta for the avoidance of double taxation and fiscal evasion with respect
to income tax.
The agreements with Macedonia and Malta, which were signed on April 14,
2008 and November 14, 2008, respectively, came into force following the Irish
ratification of the conventions on January 12, 2009 and January 15, 2009, respectively.
Both treaties will come into effect on January 1 2010.
In the case of both agreements, the conventions cover taxes on the income of
individuals and companies. They will operate by either granting exclusive taxation
rights to one or other country, or where the income or gain remains taxable
in both, by providing that the country of residence of the taxpayer will relieve
double taxation by allowing a credit for the tax paid in the other country.
The convention with Malta comprises of a nil rate of withholding tax on interest
payments and reduced rates of withholding taxes on dividends, and royalty payments.
The agreement also includes a non-discrimination article, which protects nationals
of each country from discriminatory tax provisions in the other, and the exchange
of information article, which is necessary to counter tax evasion.
With regards to the Convention with Macedonia the taxes covered by the agreement
are: personal income tax and profit tax in Macedonia, and in Ireland, personal
income tax, corporation tax and capital gains. As with the agreement with Malta
the agreement includes a non-discrimination article, mutual agreement procedure
and an agreement for the exchange of information.
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