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ARTICLE 29
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Entry into Force
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1. This Convention shall be subject to ratification in accordance with the applicable procedures of each Contracting State and instruments of ratification shall be exchanged as soon as possible.
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2. This Convention shall enter into force upon the exchange of instruments of ratification and its provisions shall have effect:
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( a ) in respect of taxes withheld at source, for amounts paid or credited on or after the first day of January next following the date on which the Convention enters into force;
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( b ) in respect of other taxes, in the case of the United States, for taxable periods, and in the case of Ireland, for financial years with respect to the corporation tax and for years of assessment with respect to the income tax and capital gains tax, beginning on or after the first day of January next following the date on which the Convention enters into force.
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3. Where the provisions of the Convention between the Government of Ireland and the Government of the United States of America for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income signed at Dublin on 13 September, 1949 (hereinafter referred to as "the 1949 Convention") would have afforded any greater relief from tax to a person entitled to its benefits than is afforded under this Convention, such provisions as aforesaid shall continue to have effect for a period of twelve calendar months from the date on which the provisions of this Convention would otherwise have effect in accordance with the provisions of paragraph 2 of this Article.
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4. The provisions of the 1949 Convention shall cease to have effect when the provisions of this Convention take effect in accordance with paragraphs 2 and 3.
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5. Subparagraph (b) of paragraph 5 of Article 23 (Limitation on Benefits) shall not have effect for a period of twenty-four calendar months from the date on which the provisions of this Convention would otherwise have effect in accordance with paragraph 2 of this Article or for a further period of twelve calendar months if paragraph 3 applies.