(1) This Convention shall enter into force on the exchange of Notes confirming that the necessary steps have been taken to give it the force of law in the United Kingdom and the Republic of Ireland, and shall thereupon have effect:
(a) in the Republic of Ireland:
(i) as respects income tax other than income tax on salaries, wages, remuneration and pensions to which Articles 15 and 18 apply, for any year of assessment beginning on or after 6 April 1976;
(ii) as respects income tax on salaries, wages, remuneration and pensions to which Articles 15 and 18 apply, for any year of assessment beginning on or after 6 April 1977;
(iii) as respects corporation tax, for the financial year 1974 and subsequent financial years;
(iv) as respects capital gains tax, for any year of assessment beginning on or after 6 April 1976. Provided that a person shall not be chargeable to capital gains tax in the Republic of Ireland for a year of assessment commencing on or after 6 April 1974 and ending on or before 5 April 1976 for which he would have been regarded as a resident of the United Kingdom under the provisions of Article 4 of this Convention, if this Convention had applied for that year.
(b) in the United Kingdom:
(i) as respects income tax other than income tax on salaries, wages, remuneration and pensions to which Articles 15 and 18 apply, for any year of assessment beginning on or after 6 April 1976;
(ii) as respects income tax on salaries, wages, remuneration and pensions to which Articles 15 and 18 apply, for any year of assessment beginning on or after 6 April 1977;
(iii) as respects corporation tax, for any financial year beginning on or after 1 April 1976;
(iv) as respects petroleum revenue tax, for any chargeable period beginning on or after 1 January 1976;
(v) as respects capital gains tax, for any year of assessment beginning on or after 6 April 1976. Provided that a person shall not be chargeable to capital gains tax in the United Kingdom for a year of assessment commencing on or after 6 April 1974 and ending on or before 5 April 1976 for which he would have been regarded as a resident of the Republic of Ireland under the 52 provisions of Article 4 of this Convention, if this Convention had applied for that year.
(2) Except as provided in paragraph (3) of this Article, the existing Agreements shall terminate upon the entry into force of this Convention as provided in paragraph (1) of this Article and thereupon cease to be effective as respects taxes to which, in accordance with paragraph (1), the present Convention applies.
(3) The existing income tax Agreement shall continue to have effect for any year of assessment ending on or before 5 April 1977 as respects income tax on salaries, wages, remuneration and pensions to which Articles 15 and 18 of this Convention apply. Provided that for the purposes of sub-paragraphs (c) and (d) of paragraph (1) of Article 2 of the said Agreement any relief granted under the provisions of Articles 11 and 21 of this Convention shall be deemed to be relief granted under the provisions of Section 27 of the Finance Act, 1920, as amended by the said Article 2.
(4) (a) In this Article the term “the existing income tax Agreement” means the Agreement made on the 14th April, 1926, between the British Government and the Government of the Irish Free State in respect of Double Income Tax; as amended by:
(i) the Agreement made on the 25th day of April, 1928, between the British Government and the Government of the Irish Free State amending the Agreement made on the 14th day of April, 1926, between the said Governments in respect of Double Income Tax;
(ii) the Agreement between the United Kingdom and the Eire Government amending the Agreement of 1926 (as amended by the Agreement of 1928) in respect of Double Income Tax dated 21st July, 1947;
(iii) the Agreement between the Government of the United Kingdom and the Government of the Republic of Ireland with respect to certain exemptions from tax dated 4th April, 1959;
(iv) the Agreement between the Government of the United Kingdom and the Government of the Republic of Ireland with respect to certain exemptions from tax dated 23rd June, 1960;
(v) the Agreement between the Government of the United Kingdom of Great Britain and Northern Ireland and the Government of the Republic of Ireland with respect to certain exemptions from tax dated 2nd May, 1973; and
(vi) the Agreement between the Government of the United Kingdom of Great Britain and Northern Ireland and the Government of the Republic of Ireland with respect to certain exemptions from tax dated 3rd June, 1975.
b) In this Article, the term “the existing Agreements” means:
(i) the existing income tax Agreement; and
(ii) the Agreement between the United Kingdom Government and the Government of the Republic of Ireland for the Reciprocal Relief of Double Taxation in respect of United Kingdom Profits Tax and Irish Corporation Profits Tax signed on 18th May, 1949, as amended by the Protocol between the Government of the United Kingdom of Great Britain and Northern Ireland and the Government of the Republic of Ireland amending the said Agreement, signed on 2nd May, 1973.