Finance Act, 1951


Relief of Double Taxation: Income Tax and Corporation Profits Tax.

Relief from double taxation on profits from business of sea or air transport.

15.—(1) In this section—

“business of sea or air transport” means the business of transporting persons, goods or mail carried on by the owner or charterer of ships or aircraft;

“arrangement to which this section applies” means an arrangement entered into by the Government with the government of a foreign state with a view to affording relief from double taxation in cases where income derived from the business of sea or air transport is chargeable both in the State and in the foreign state to income tax, or to any tax corresponding to income tax, or to any other tax on profits, whether such arrangement is to afford relief as from the date when it is entered into, a date after that date or a date (including a date before the passing of this Act) before that date.

(2) Subject to subsections (3) and (4) of this section, the Government may by order confirm and give the force of law to an arrangement to which this section applies.

(3) Where an order is proposed to be made under this section, a draft thereof shall be laid before Dáil Eireann and the order shall not be made until a resolution approving of the draft has been passed by Dáil Eireann.

(4) Where an order is made under this section, the arrangement to which it relates shall have the force of law only if and so long as such arrangement, in so far as it relates to the relief to be granted by the foreign state, has the force of law in that state.