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1Article 1 · Personal Scope2Article 2 · Taxes Covered3Article 3 · General Definitions4Article 4 · Fiscal Domicile5Article 5 · Permanent Establishment6Article 6 · Limitation of Relief7Article 7 · Income From Immovable Property8Article 8 · Business Profits9Article 9 · Shipping and Air Transport10Article 10 · Associated Enterprises11Article 11 · Dividends12Article 12 · Interest13Article 13 · Royalties14Article 14 · Capital Gains14aArticle 14A · Charities and Superannuation Schemes: Additional Provisions15Article 15 · Employments16Article 16 · Artistes and Athletes17Article 17 · Pensions17aArticle 17A · Pension Scheme Contributions18Article 18 · Government Service19Article 19 · Students20Article 20 · Income Not Expressly Mentioned21Article 21 · Elimination of Double Taxation22Article 22 · Personal Allowances23Article 23 · Non-Discrimination24Article 24 · Mutual Agreement Procedure25Article 25 · Exchange of Information26Article 26 · Diplomatic and Consular Officials27Article 27 · Territorial Extension28Article 28 · Entry Into Force29Article 29 · TerminationPreamble · Title, publisher explanation and complete preambleSignature · Signature and authentic-language clause

31 articles · English

Source & edition
Country pairs / United Kingdom / Ireland

United Kingdom / Ireland · United Kingdom–Ireland 1976 Convention: official MLI synthesis

Article 3 · General Definitions

English · synthesized source publication

Unreviewed · applicability unverifiedOfficial MLI synthesis
Original & source
§
(1) In this Convention, unless the context otherwise requires:
§
(a) the term “Republic of Ireland” includes any area outside the territorial waters of the Republic of Ireland which in accordance with international law has been or may hereafter be designated, under the laws of the Republic of Ireland concerning the Continental Shelf, as an area within which the rights of the Republic of Ireland with respect to the sea bed and subsoil and their natural resources may be exercised;
§
(b) the term “United Kingdom” includes any area outside the territorial sea of the United Kingdom which in accordance with international law has been or may hereafter be designated, under the laws of the United Kingdom concerning the Continental Shelf, as an area within which the rights of the United Kingdom with respect to the sea bed and subsoil and their natural resources may be exercised;
§
(c) the term “nationals” means:
§
(i) in relation to the Republic of Ireland, all citizens of Ireland and all legal persons, associations or other entities deriving their status as such from the laws in force in the Republic of Ireland;
§
(ii) in relation to the United Kingdom, citizens of the United Kingdom and Colonies, British subjects under Section 2 of the British Nationality Act 1948 whose notices given under that Section have been acknowledged before the date of signature of this Convention, British subjects by virtue of Section 13 (1) or Section 16 of the British Nationality Act 1948 or Section 1 of the British Nationality Act 1965, and British protected persons within the meaning of the British Nationality Act 1948; and all legal persons, associations or other entities deriving their status as such from the law in force in the United Kingdom;
§
(d) the term “United Kingdom tax” means tax imposed by the United Kingdom being tax to which this Convention applies by virtue of the provisions of Article 2; the term “Irish tax” means tax imposed by the Republic of Ireland being tax to which this Convention applies by virtue of the provisions of Article 2;
§
(e) the term “tax” means United Kingdom tax or Irish tax, as the context requires;
§
(f) the terms “a Contracting State” and “the other Contracting State” mean the United Kingdom or the Republic of Ireland, as the context requires;
§
(g) the term “person” comprises an individual, a company and any other body of persons;
§
(h) the term “company” means any body corporate or any entity which is treated as a body corporate for tax purposes;
§
(i) the terms “enterprise of a Contracting State” and “enterprise of the other Contracting State” mean respectively an enterprise carried on by a resident of a Contracting State and an enterprise carried on by a resident of the other Contracting State;
§
(j) the term “competent authority” means, in the case of the United Kingdom, the Commissioners of Inland Revenue or their authorised representative, and in the case of the Republic of Ireland, the Revenue Commissioners or their authorised representative.
§
(2) As regards the application of this Convention by a Contracting State any term not otherwise defined shall, unless the context otherwise requires, have the meaning which it has under the laws of that Contracting State relating to the taxes which are the subject of this Convention.
Citation to select or copy

United Kingdom / Ireland; HMRC, Synthesised text of the Multilateral Instrument and the 1976 UK-Ireland Double Taxation Convention; edition Official MLI synthesis, including 1976, 1994 and 1998 Protocol amendments; HMRC updated 13 August 2019; article 3; English; unreviewed source text, current applicability unverified; /editions/gb-ie-1976-hmrc-mli-synthesis-html-v1/en/articles/article-3/

Disclaimers

Unreviewed machine transcription. Not a verified current-law consolidation or legal advice. Later changes may be missing.

Language switching retains source identifiers only. This is not reviewed legal or translational equivalence.

Page links are source references, not verified paragraph correspondence. Formatting and extraction errors may remain.

Noindex is not access control. This is a research preview, not a statement of authoritative or current law.

Source & edition

HMRC, Synthesised text of the Multilateral Instrument and the 1976 UK-Ireland Double Taxation Convention

  • Official online text · retained capture Official source website ↗

    SHA-256 5ffd22e3bb53003e6d7254f53be2f02f502e2ae931e38136a3983f7bb1325162

    Digest scope: retained online-source capture; no PDF binary verification

Edition
Official MLI synthesis, including 1976, 1994 and 1998 Protocol amendments; HMRC updated 13 August 2019
Text available here
English
Review
Unreviewed; qualified human review pending
Current applicability
Not verified
Signature
1976-06-02

Languages recorded in source metadata: English. This is not a promise of available text or a translation.

Edition notes and known limitations

Official HTML text capture, not Original PDF; human wording and current-law certification not claimed.

Block IDs are navigation aids, never invented legal paragraph numbers. Native extraction can flatten ordered-list styling; only printed source labels are retained.

Complete preamble, closing and all supplied integral protocol/notes are retained separately and searchable within this source.

Publisher synthesis, not an authentic treaty instrument. MLI replacement text and explanations are retained; original boxes/layout are not reproduced. Authentic Convention and MLI texts take precedence.

Source authority, text completeness and currentness still require human review.

Retained metadata & integrity record

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