(Information from the Irish Tax Commissioners) In 1997, a new double taxation agreement was signed between Ireland and the United States, replacing the treaty in force since 1951. One of the main changes to the new contract was the tax treatment of U.S. Social Security pensions. All beneficiaries of a U.S. social security pension residing in Ireland are now exempt from the withholding tax on these pensions in the United States. However, effective 6 April 1998, all of these pensions are taxable in Ireland, subject to the normal limits of the Irish tax exemption. See below a summary of the ongoing work on negotiating new DBAs and updating existing agreements: Ireland has signed a comprehensive double taxation agreement (DBA) with 74 countries; 73 are in effect. The agreements deal with direct taxes, as is the case in Ireland: Ireland has comprehensive double taxation agreements with 73 countries. An agreement with Ghana is still being ratified and negotiations with Kenya, Kosovo, Oman and Uruguay have been concluded. Agreements generally cover personal income tax, corporate and capital gains tax, as well as general levy.
Copies of the Irish/AMERICAN Double Taxation Convention are available on the Revenue – www.revenue.ie – website in double taxation publications/conventions. Copies can also be purchased at the Government Publications Sale Office, Sun Alliance House, Molesworth Street, Dublin 2 or any bookseller – priced at 10.68 euros. Almost all Irish contracts provide for a zero-source tax on interest paid to a contractor, either unconditionally or only on certain types of interest. The exceptions are contracts with Australia, Chile, Israel and Turkey, which provide for lower but not zero interest rates for interest payments. Many Irish tax agreements also exempt royalties paid by Irish companies from withholding tax. All persons residing in Ireland who receive a social security pension in the United States should contact their local tax inspector to ensure that the correct tax treatment applies to their income. Ireland has ratified the Multilateral Convention on the Implementation of Measures to Prevent BEPS (MLI) in the 2018 Finance Act. It came into force in Ireland on 1 May 2019.