Section 826A Unilateral relief from double taxation
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Amendments
Section 826A inserted by Finance Act 2007 section 36(1)(a) in the case of relief from corporation tax, as respects an accounting period ending on or after 1 January 2007, and in any other case, for 2007 and later tax years.
Where relief from double taxation is not afforded by virtue of section 826, relief (known as "unilateral relief") from tax shall be given in respect of tax paid under the laws of a territory other than the State in accordance with Schedule 24.
If a DTA doesn't specifically provide for relief, can any relief be obtained?
Double tax relief only applies where the treaty in question allows such relief. For example, Ireland's treaty with France provides relief from double taxation in relation to income tax and corporation tax but not capital gains tax. ...
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