Vol. 461 No. 7
122 Mr. D. Ahern asked the Minister for Finance if Ireland has entered into the mutual agreement procedures as required under article 24, section 3 of the Double Taxation Agreement, 1976, made between the United Kingdom and the Republic of Ireland; and if he will make a statement on the matter. [3870/96]
Article 24 (3) of the Ireland/UK Double Taxation Convention, 1976 provides as follows:
"The competent authorities of the Contracting States shall endeavour to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of the Convention".
This article was entered into by Ireland on the Convention's ratification in 1976.
Mutual agreement procedures are a common feature of double taxation conventions. They enable the Competent authorities of the Contracting States to enter into discussions on difficult or doubtful cases in order to ensure that taxpayers obtain the double taxation relief provided for under the conventions.
The Revenue Commissioners are the Irish Competent Authority for the purposes of the Ireland/UK Convention. I have been advised by them that the mutual agreement procedures provided for in the Convention have been used on a number of occasions and have worked well.
