French investors interested in the business environment available in Ireland
should know that they can benefit from the provisions of the double taxation treaty (DTA)
signed by France and Ireland
. The treaty
between the two states was signed in March 1968 and it entered into force in 1971. The agreement stipulates the taxes applied by the French
parties, in order to avoid the double taxation
of individuals and legal entities carrying out various taxable activities on the territory of the both countries. French businessmen who want to find out more details on the tax deductions they are entitled to, can receive an in-depth presentation from our team of Irish solicitors
Taxes under the France- Ireland DTA
It is important to know that France will impose the following income taxes, as prescribed by the local legislation:
• the tax on income of individuals;
• the complementary tax;
• tax on companies, which refers also to the withholding tax.
According to the agreement, Ireland will impose the following two taxes:
• the corporation profits tax.
The difference between taxes
applicable in the two contracting states is given by the local taxation system
available in each country, but it should be mentioned that the parties have agreed to impose similar taxes
; our team of Irish attorneys
can provide more information in this sense.
The permanent establishment under the DTA
The France-Ireland DTA
provides a definition for the understanding of the permanent establishment (PE)
, which can be a fixed place of business in which a company
carries out its operations (the meaning is still applicable for companies which carry only parts of their operations in one of the contracting state).
can refer to a branch
, an office, a factory or a mine, but also a construction site in which the operations are carried out for a period longer than a year. The term is very important for the France-Ireland DTA
because if a French company
operates in Ireland
through a PE, its business profits will be taxed in Ireland
, but only for the income obtained through the PE; but as a general rule, a French company
will be taxed for its income in France.