1. Items of income beneficially owned by a resident of a Contracting State, wherever arising, not dealt with in the foregoing Articles of this Convention shall be taxable only in that State.
2. The provisions of paragraph 1 shall not apply to income, other than income from immovable property as defined in paragraph 2 of Article 6 (Income from Immovable Property (Real Property)), if the beneficial owner of the income, being a resident of a Contracting State, carries on business in the other Contracting State through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the income is attributable to such permanent establishment or fixed base. In such case the provisions of Article 7 (Business Profits) or Article 14 (Independent Personal Services), as the case may be, shall apply.
Citation to select or copy
Ireland / United States; S.I. No.477/1997, Schedule; edition Convention signed 28 July 1997, as printed in S.I. No.477/1997; not incorporating 1999 amendment; article 22; English; unreviewed source text, current applicability unverified; /editions/ie-us-1997-convention-irish-si477/en/articles/article-22/
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Edition
Convention signed 28 July 1997, as printed in S.I. No.477/1997; not incorporating 1999 amendment
Text available here
English
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