Income Tax Act, 1967.

Further relief for certain double residents.

356.—Where the Revenue Commissioners are satisfied in respect of any person—

(a) that such person is entitled under Article 2 of the Agreement made 25th April, 1928, set forth in Schedule 6, Part I, to be allowed relief from double taxation for any particular year, and

(b) that the principal place of abode of such person for the said year was situate in Northern Ireland or Great Britain, and

(c) that such person did not in the said year spend in the aggregate more than six months in the State, and

(d) that the total amount of income tax and sur-tax (including British as well as Irish income tax and sur-tax) payable by such person for the said year after deduction of all such relief from double taxation as aforesaid exceeds the total amount of British income tax and sur-tax which would have been payable by such person for the said year if he had not been resident in the State for that year,

the Revenue Commissioners may grant to such person such further relief from Irish income tax and sur-tax as in their opinion is just, but not exceeding the amount by which the total amount of income tax and sur-tax (including British as well as Irish income tax and sur-tax) mentioned in paragraph (d) exceeds the total amount of British income tax and sur-tax mentioned in that paragraph.