Taxes Consolidation Act 1997 Schedule 24 paragraph 2

Double taxation relief - General

Paragraph 2 of Schedule 24 sets out the general rules for allowing credit for foreign tax paid against Irish tax chargeable on the same income under double taxation arrangements.

• Where a double taxation agreement provides for credit, the Irish tax on the relevant income is reduced by the amount of the foreign tax credit.
• For income within the charge to corporation tax, the credit is applied against the company's corporation tax liability on that income.
• For income within the charge to income tax, the credit must first be applied against income tax before any other Irish tax on that income.
• No credit may be taken for any foreign tax unless the relevant double taxation agreement specifically authorises it, and no credit is available for any tax that is a qualified IIR or qualified UTPR under section 111A.