Dáil Éireann debate -
Tuesday, 31 Jan 1995

Vol. 448 No. 3

Written Answers. - Double Taxation Requirements.

James McDaid

Question:

58 Dr. McDaid asked the Minister for Finance the result of recent discussions and negotiations regarding double taxation agreements with Austria, Finland, France, Greece and Italy; and the reason no renegotiations have taken place with the United Kingdom since 1976. [2039/95]

Minister for Finance (Mr. Quinn)

Double taxation treaties are primarily entered into to facilitate commercial and other relations between Ireland and other countries. Such treaties eliminate, where possible, incidences of double taxation.

Major changes were introduced in the Irish taxation system in the 1970s with the introduction of capital gains tax and corporation tax. Older double taxation treaties entered into by Ireland prior to 1976 did not adequately reflect the new tax regime and it has been necessary over time, and as staff resources permit, to update these treaties. Current policy with regard to the negotiation of double taxation treaties is to extend our network of treaties and to update older treaties.

The negotiations listed below, therefore, took place either to broaden Ireland's network of double taxation treaties or to update existing treaties to take account of changes in our taxation rules or those of our partner countries since the original treaties were signed.

Austria: Discussions have taken place at official level between the Revenue Commissioners and Austrian officials on a Protocol to amend the existing treaty between the two countries. Further discussions on this Protocol will probably be necessary before it can be presented to Government for approval.

Finland: A new treaty with Finland entered into force in December 1993. No further negotiations have taken place in the interim.

France: Negotiations on a replacement treaty have taken place at official level. Further negotiations will be necessary before the text of the new treaty is finalised.

Greece: Negotiations on a treaty have reached an advanced stage. It is hoped that this treaty will be signed during the coming year.

Italy: Negotiations on a replacement treaty have taken place at official level and are also at an advanced stage. It is hoped that this treaty will be signed during the coming year.

United Kingdom: The 1976 treaty with the United Kingdom was the first treaty signed by Ireland following the introduction of the tax changes of the 1970s. In this respect it is a relatively modern treaty and comprehensively caters for the tax regimes of both countries. A Protocol amending this treaty was signed in November 1994 so as to make a minor adjustment to the provisions. This Protocol provides for the addition to the treaty of a new article which provides for the recognition by each State, in certain circumstances, of occupational pension schemes of the other State where such schemes have members in both countries. The addition of this provision was necessary to take account of changes in UK pensions tax law since the signature of the treaty.