asked the Minister for Finance if he will fully explain the position with regard to income tax of a person who during the course of a financial year returned from Britain to this country, who paid tax on his British earnings, but whose residence in this country was sufficiently long to make him liable for income tax for the year in question here; and if he will state whether such a person's British earnings, in addition to his Irish earnings, are liable to Irish income tax.
Ceisteanna—Questions. Oral Answers. - Liability for Income Tax.
2.
On the assumption that the person referred to was resident for income tax purposes in Britain as well as in this country for the financial year in question, he is liable to the tax of each country. His British earnings, in addition to his Irish earnings, are liable to Irish income tax.
Under the Double Income Tax Agreements, however, in force between this country and Britain he is given double taxation relief by each country in respect of the doubly-taxed income at one-half of the lower of his two appropriate rates of tax, Irish and British. The effect of the relief is to eliminate the smaller of the two taxes on the doubly-taxed income—leaving him ultimately to bear, as between the two countries, the bigger of the two taxes.
Questions of residence and the application of the Double Taxation Agreements are technical matters and, if the Deputy has a particular case in mind, he might perhaps care to send me the details and I shall be happy to look into it.