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FINANCE ACT, 1973
Between the Government of Ireland and the Government of the United Kingdom Amending the Agreement for the Reciprocal Relief of Double Taxation in Respect of Irish Corporation Profits Tax and United Kingdom Profits Tax, Signed on 18th May 1949
The Government of Ireland and the Government of the United Kingdom;
Desiring to conclude a Protocol to amend the Agreement between the Contracting Parties for the reciprocal relief of double taxation in respect of Irish Corporation Profits Tax and United Kingdom Profits Tax, signed on 18th May 1949 (hereinafter referred to as “the Agreement”);
Have agreed as follows:
In Article VII (1) and (2) of the Agreement for the words “beneficially owns, directly or indirectly, not less than three-quarters of the ordinary share capital of” there shall be substituted the words “controls, directly or indirectly, not less than 10 per cent. of the voting power in”.
This Protocol, which shall form an integral part of the Agreement, shall come into force when the last of all such things shall have been done in Ireland and the United Kingdom as are necessary to give the Protocol the force of law in Ireland and the United Kingdom respectively, and shall thereupon have effect in respect of dividends paid on or after 6th April 1973.
In witness whereof the undersigned, duly authorised thereto by their respective Governments, have signed this Protocol.
Done in two originals at London this 2nd day of May, 1973.
For the Government of Ireland:
For the Government of the United Kingdom: