The provisions of the Double Taxation Treaty between Ireland and Israel do not apply to territories occupied by Israel in 1967. An individual will not be treated as a resident of Israel for the purposes of the Treaty by virtue of their residing in occupied territories nor will a company be treated as resident in Israel by virtue of its being established in occupied territories. Similarly, for the purposes of the Treaty, income arising in Israel does not include income from sources within occupied territories. Such circumstances are not within the scope of the Treaty. There is no entitlement to benefits under the terms of the Treaty by virtue of such circumstances involving individuals residing, or companies established, in occupied territories nor with respect to income from sources within those territories.
I am informed by the Revenue Commissioners that all double taxation treaty reliefs or benefits must be in accordance with the scope of the double taxation treaty concerned and that, while there are not procedures or inspections specific to the Ireland-Israel Treaty, Revenue will challenge any relief or benefit that it has reason to believe is not in accordance with the terms of a relevant treaty.
