Does an Irish Small Self Administered Pension Scheme qualify for benefits under the UK/IRE Double Taxation Agreement? Specifically is interest earned on a loan to a UK person subject to UK withholding tax?
I quote from the relevant DTA as follows:
For the purposes of this Convention, the term “resident of a Contracting State” means, subject to the provisions of paragraphs (2) and (3) of this Article, any person who, under the law of that State, is liable to taxation therein by reason of his domicile, residence, place of management or any other criterion of a similar nature; the term does not include any individual who is liable to tax in that Contracting State only if he derives income from sources therein. The terms “resident of the United Kingdom” and “resident of the Republic of Ireland” shall be construed accordingly.