in Ireland. Subject to the provisions of the laws of Ireland regarding the allowance as a credit against Irish tax of tax payable in a territory outside Ireland (which shall not affect the general principle hereof) – (a) Albanian tax payable under the laws of Albania and in accordance with this Agreement, whether directly or by deduction, on profits, income or gains from sources within Albania (excluding in the case of a dividend tax payable in respect of the profits out of which the dividend is paid) shall be allowed as a credit against any Irish tax computed by reference to the same profits, income or gains by reference to which Albanian tax is computed; (b) in the case of a dividend paid by a company which is a resident of Albania to a company which is a resident of Ireland and which controls directly or indirectly 5 per cent or more of the voting power in the company paying the dividend, the credit shall take into account (in addition to any Albanian tax creditable under the provisions of subparagraph (a) of this paragraph) Albanian tax payable by the company in respect of the profits out of which such dividend is paid.
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Samples: Agreement for the Avoidance of Double Taxation, Double Taxation Agreement
in Ireland. Subject to the provisions of the laws of Ireland regarding the allowance as a credit against Irish tax of tax payable in a territory outside Ireland (which shall not affect the general principle hereof) –-
(a) Albanian tax payable under the laws of Albania and in accordance with this Agreement, whether directly or by deduction, on profits, income or gains from sources within Albania (excluding in the case of a dividend tax payable in respect of the profits out of which the dividend is paid) shall be allowed as a credit against any Irish tax computed by reference to the same profits, income or gains by reference to which Albanian tax is computed;
(b) in the case of a dividend paid by a company which is a resident of Albania to a company which is a resident of Ireland and which controls directly or indirectly 5 per cent or more of the voting power in the company paying the dividend, the credit shall take into account (in addition to any Albanian tax creditable under the provisions of subparagraph (a) of this paragraph) Albanian tax payable by the company in respect of the profits out of which such dividend is paid.
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