- Notices of Tax Treaty Developments - Status of Tax Treaties

Tax Convention Signed Between Canada and Ireland

October 10, 2003


A new Convention between Canada and Ireland for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and capital gains was signed on October 8, 2003 in Ottawa.

The Convention limits the rate of withholding tax to 5% for dividends between affiliated companies, 15% for dividends in all other cases, and 10% for interest. The Convention limits the rate of withholding tax to 10% for royalties and provides an exemption in respect of certain copyright royalties and for certain payments made for the use of any patent, computer software, and for information concerning industrial, commercial or scientific experience.

The Convention will enter into force once Canada and Ireland have notified each other that all the necessary measures to give the Convention the force of law in their respective countries have been completed. In the case of Canada, the Convention will have effect, in respect of tax withheld at the source, on amounts paid or credited to non-residents on or after the first day of January in the calendar year next following that in which the Convention enters into force; and, in respect of other Canadian tax, for taxation years beginning on or after the first day of January in the calendar year next following that in which the Convention enters into force. In the case of Ireland, the Convention will have effect, in respect of income tax and capital gains tax, for any year of assessment beginning on or after the first day of January in the calendar year next following that in which the Convention enters into force; and, in respect of corporation tax, for any financial year beginning on or after the first day of January in the calendar year next following that in which the Convention enters into force.

The existing Agreement between the Government of Canada and the Government of Ireland for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income signed at Ottawa on November 23, 1966, shall cease to have effect from the dates on which the Convention becomes effective. The Agreement shall terminate on the last date on which it has effect.

For further information contact:
Parry Athenaios
Tax Legislation Division
Phone: (613) 992-5864