Taxes Consolidation Act 1997 section 832

Provisions in relation to Convention for reciprocal avoidance of double taxation in the State and the United Kingdom of income and capital gains

Section 832 deals with the application of the Ireland–United Kingdom double taxation convention (SI 319/1976) and provides special rules for UK friendly societies carrying on life assurance business in the State.

• The "Convention" is the 1976 double taxation agreement between Ireland and the United Kingdom, as set out in SI 319/1976
• The Tax Acts apply subject to the modifications in section 73, which restrict the remittance basis for UK-source income and align the basis of computation with Irish rules
• UK friendly societies carrying on life assurance business in the State may only deduct management expenses attributable to contracts made on or after 6 April 1976
• Income attributable to pre-6 April 1976 contracts is excluded when computing a UK friendly society's liability to Irish corporation tax