Treaty detail
United Kingdom - Ireland tax treaty
A practical treaty page built around the official treaty text, key withholding categories, permanent-establishment rules, and article-level summaries.
Signed
1976-06-02
Effective
1976-12-23
Articles seeded
6
Withholding snapshot
Dividends
Individual rate: 15% · Corporate rate: 5%
The lower 5 percent corporate rate generally depends on direct-ownership thresholds. Ireland's domestic dividend exemption may eliminate withholding for many qualifying corporate recipients independently of the treaty.
Interest
Rate: 0%
The treaty generally results in zero source-country withholding on qualifying interest. Ireland's domestic exemptions also apply in many cases independently of the treaty.
Royalties
Rate: 0%
The treaty generally eliminates source-country royalty withholding across the major categories under the article.
Permanent establishment
Construction threshold: more than 12 months
Dependent-agent analysis follows the treaty wording as amended by protocol.
Other treaty flags
Pension treatment is article-specific and is generally favorable for cross-border pension arrangements between the two jurisdictions.
Seeded article summaries
Article 4
Residence
Defines treaty residence under the 1976 wording as amended by protocols.
Article 4 has been amended several times by protocol. Residence analysis under the treaty interacts with Ireland's relatively flexible holding-company provisions.
Article 5
Permanent Establishment
Sets the business-presence threshold with a 12-month construction rule.
The treaty uses the standard 12-month construction-site threshold as amended by protocol.
Article 7
Business Profits
Generally reserves business profits to the residence state in the absence of a PE.
Article 7 is the operating rule for cross-border services. Given Ireland's role as a common holding-company jurisdiction, this article frequently matters for Irish-resident groups with UK activity.
Article 10
Dividends
Caps source-country withholding on dividends at treaty rates that vary with shareholding.
Article 10 produces the 15 percent and 5 percent treaty ceilings. Ireland's domestic dividend exemption may eliminate Irish-source withholding for many qualifying corporate recipients.
Article 11
Interest
Generally removes source-country withholding on qualifying interest.
Article 11 typically eliminates source-country withholding on qualifying interest, complementing Ireland's domestic exemption regime.
Article 12
Royalties
Generally removes source-country withholding on qualifying royalties.
Article 12 eliminates source-country royalty withholding across the major categories under the article.
Official text
Other treaties involving these jurisdictions
Computed from the cross-reference graph. Links open the related entity on this site.
This entry cites
- TreatyUS–GB treaty
- TreatyUS–IE treaty
- TreatyGB–CA treaty
- TreatyGB–AU treaty
- TreatyGB–DE treaty
- TreatyGB–FR treaty
- TreatyGB–JP treaty
- TreatyGB–NL treaty
Primary sources
- HMRC: Ireland tax treatyVerified 2026-05-20
- Irish Revenue: double taxation treatiesVerified 2026-05-20
- OECD MLI matching databaseVerified 2026-05-20
Important disclaimer
This library is for general tax education only. Always verify filing obligations, due dates, and tax consequences against the cited primary source or with a qualified tax professional.