4. In this article, the term „taxation” refers to the taxes that are the subject of this agreement. (a) at least 95%. gross revenues of the former corporation for each of its last three full tax years before the date the dividend was paid or credited (or, in the case of a corporation less than three years, for each full fiscal year prior to that date), received by the corporation or by non-residents who, or instead of paying dividends or interest , and 2. Tax authorities of contracting governments may communicate directly with each other to implement the provisions of this agreement and resolve any difficulties or doubts about the application or interpretation of the agreement. (ii) for other Canadian taxes for fiscal years beginning on the first day of January or after the first day of January, in the calendar year following the one in which ratification instruments are exchanged. Double taxation agreements are very useful things for people like you who have business interests, assets or income in more than one jurisdiction. Otherwise, you would be taxed in isolation according to the rules of each state. And this can often lead you to be taxed twice on the same income. 1.
Nationals of one territory are not subject to a tax or requirement in another territory that is different or more burdensome than the imposition and related requirements to which nationals of that other territory are subject or may be subject in the same circumstances. 3. The agreement between the Irish government and the Government of Canada, signed in Ottawa on October 28, 1954, on the prevention of double taxation and the prevention of income tax evasion, is denounced and extinguished for any period for which this agreement takes effect in accordance with paragraph 2 of this article. 3 Where a person other than a person resides in the two contracting states under paragraph 1 of this article, the competent authorities of the contracting states endeavour, by mutual agreement, to clarify the question of which contracting state that person should be considered resident solely for the purposes of the convention and, the place where it is received or otherwise founded. , as well as all other relevant factors. In the absence of such an agreement, that person has no right to accept or exempt stewardship, unless the competent authorities of the contracting states have benefited from an exemption or exemption from tax. At the end of the day, in Ireland, I pay about 10 per cent of the tax on that income that is already taxed in Canada.