Treaty detail
United States - Ireland tax treaty
A practical treaty page built around the official treaty text, key withholding categories, permanent-establishment rules, and article-level summaries.
Signed
1997-07-28
Effective
1998-01-01
Articles seeded
6
Withholding snapshot
Dividends
Individual rate: 15% · Corporate rate: 5%
The lower 5 percent corporate rate generally depends on a direct-ownership threshold under the treaty. Certain pension and qualifying-entity cases may obtain further reductions.
Interest
Rate: 0%
The treaty article generally results in zero source-country withholding on qualifying interest, subject to beneficial-ownership and treaty-qualification analysis.
Royalties
Rate: 0%
Most royalties are generally exempt from source-country withholding under the treaty when treaty conditions are met.
Permanent establishment
Construction threshold: more than 12 months
Dependent-agent analysis remains important where a person habitually concludes contracts in the name of the enterprise under the treaty wording.
Other treaty flags
Pension treatment is article-specific. The treaty includes detailed pension and government-service articles that can alter the general result.
Seeded article summaries
Article 4
Residence
Defines treaty residence for U.S.-Ireland treaty purposes and includes tie-breaker analysis.
Article 4 is the starting point for treaty entitlement and matters for dual residents and for entities whose residence is determined under domestic law in both states.
Article 5
Permanent Establishment
Sets the business-presence threshold with a 12-month construction rule.
The Ireland treaty uses the classic 12-month construction-site threshold. Agency-related PE analysis remains relevant where a person habitually exercises authority to conclude contracts in the name of the enterprise.
Article 7
Business Profits
Generally reserves business profits to the residence state unless a permanent establishment exists in the other state.
Article 7 is the operating rule for cross-border services and exports. Because Ireland has been a common holding-company jurisdiction, this article frequently matters alongside Article 22 limitation-on-benefits analysis.
Article 10
Dividends
Caps source-country withholding on dividends at treaty rates that vary with shareholding.
Article 10 produces the 15 percent portfolio rate and the lower 5 percent direct-investment rate. The treaty interacts with U.S. limitation-on-benefits analysis, which can affect the availability of the lower rate.
Article 11
Interest
Generally removes source-country withholding on qualifying interest.
Article 11 typically eliminates source-country withholding on qualifying interest. Beneficial-ownership analysis remains important, particularly given the historical use of Irish structures as conduits.
Article 12
Royalties
Generally removes source-country withholding on qualifying royalties.
Article 12 is especially valuable for software, licensing, and IP structures because the treaty produces a zero-percent result across the major royalty categories. Limitation-on-benefits analysis still matters.
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–CA treaty
- TreatyUS–DE treaty
- TreatyUS–FR treaty
- TreatyUS–JP treaty
- TreatyUS–NL treaty
- TreatyUS–AU treaty
- TreatyUS–KR treaty
Primary sources
- IRS Ireland treaty documents pageVerified 2026-05-20
- Official U.S.-Ireland treaty PDFVerified 2026-05-20
- IRS Tax Treaty Table 1Verified 2026-05-20
- Irish Revenue Commissioners - double taxation treatiesVerified 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.