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Ireland signs Double Tax treaty with Armenia

AUTHOR(S): Gerry Thornton
PRACTICE AREA GROUP: Tax
DATE: 01.09.2011

Ireland signed a double tax treaty with Armenia on 14 July 2011 bringing to 63 the number of tax treaties which Ireland has signed. The treaty substantially follows the OECD model convention in dealing with issues such as residence, permanent establishment and exchange of information.

The treaty provides for reduced rates of withholding tax on dividends, interest and royalties. The maximum rate of withholding tax on dividends will be 15%.  However, this will be reduced to nil where a 25% shareholding has been held for two years and the recipient is generally relieved from tax in respect of the dividends (either by way of credit or exemption).  The maximum rate of withholding tax for interest will be 10%.  However, Ireland has agreed (in a protocol) to unilaterally apply a nil rate of interest withholding tax on payments to residents of Armenia.  In return, Armenia has agreed that the 10% rate provided by the treaty will automatically reduce to match any lower rate in a double tax treaty signed by Armenia with any other OECD country after July 2011. In the meantime, Irish banks will benefit from a lower 5% rate on interest payments from Armenia and Irish government enterprises have a full exemption.

Finally, the protocol also provides an interesting definition of the ‘place of effective management’ as “the place where a company is actually managed and controlled, the place that plays the leading part in the management of a company from an economic and functional point of view and the place where the accounting books are kept”. This is a new definition which Ireland has not used in any of its previous treaties.

The signing of this treaty reflects a concerted effort by Ireland to extend its treaty network to the countries of Eastern Europe and Western Asia. Negotiations are ongoing or have recently been concluded with Azerbaijan, Ukraine and Uzbekistan as well as Saudi Arabia, Thailand, Egypt, Tunisia and Panama.

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This material provides a broad summary of the matters referred to herein, and is not intended to provide, and does not constitute, legal or any other advice on any particular matter, and is provided for general information purposes only.

For further information, please contact Gerry Thornton

 

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