5 For the purposes of Article XXII, paragraph 3 (Consultation) of the General Convention on Trade in Services, States Parties agree that, notwithstanding this paragraph, any dispute between them as to whether a measure falls within the scope of this Convention can only be submitted to the Council for Trade in Services covered by this paragraph with the agreement of the two States Parties. Any doubts about the interpretation of this paragraph are removed in accordance with paragraph 4 of Article 25 or, in the absence of agreement under that procedure, under another procedure agreed by the two States Parties. 6 No provision of this Convention should be construed as preventing a contracting state from taxing the income of a corporation that can be added to a stable institution in that state, in addition to the tax that would be levied on the income of a corporation that is a national of that state, provided that any additional tax thus collected does not exceed 5% of the amount of that income which is not subject to those additional incomes. Taxes on previous years. For the purposes of this provision, “benefits” are defined as profits attributable to a stable establishment located in a contracting state (including profits from the disposal of property belonging to the commercial property of such an establishment) in a year and in previous years after deduction of: 2 The competent authority in paragraph 1 applies where the objection is justified and is not in a position to do so itself. to achieve a satisfactory result. A solution to settle the matter by mutual agreement with the competent authority of the other State party in order to avoid an imposition that is not in accordance with the provisions of this convention. When it comes to paying taxes in Ireland, I understand that I have to report those Canadian revenues and, in accordance with the double taxation agreement, I have credits for that. CONSIDERING that it is adopted by Section 361 (1) of the Income Tax Act 1967 (No.
6 of 1967) only when the government declares on behalf that double taxation exemption agreements have been concluded with the government of a territory outside the state with respect to personal income tax, surcharges or similar taxes. , imposed by the laws of the state or by the laws of that territory and that it is appropriate that these provisions have the force of law, regardless of the instates, the rules have the force of law: Ireland and Canada have entered into a tax treaty with a double taxation convention that should prevent double taxation of the same income, so it is important to use it.