Ireland Signs Double Taxation Avoidance Agreement With Chile

by Jason Gorringe, Tax-News.com, London

08 June 2005

In Dublin Castle last week, Mr Frank Daly, Chairman of the Revenue Commissioners, and Mr Juan Toro Rivera, Commissioner, Internal Revenue Service, Chile, last week signed a 'Convention between Ireland and the Republic of Chile for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and capital gains.'

The Convention is comprehensive in scope and applies to direct taxes (in Ireland, income tax, corporation tax and capital gains tax). It also provides for reduced source country taxation of interest and royalties payments.

Other important Articles in the Convention include non-discrimination provisions which protect nationals of each country from discriminatory tax provisions in the other and also exchange of information provisions, which are necessary to counter fiscal evasion.

The Convention provides for the allocation of taxing rights between Ireland and Chile. Where items of income or gains remain taxable in both countries, double taxation is relieved by the country of residence granting credit against its tax for the tax paid in the other country.

The Convention is expected to have a generally positive impact on trade and investment between Ireland and Chile, which has a market-oriented economy characterised by a high level of foreign trade. During the 1990s Chile was South America’s fastest growing economy and given continuing steady economic growth in Chile the Convention will significantly assist future Irish business and investment there.

If, as is expected, that the Convention is ratified by the Dáil and the Parliament of Chile during 2005, it will enter into force at the beginning of 2006.

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