With reference to paragraph 2 of Article. 23 Where a resident of Singapore derives income from Ireland and Singapore accords exemption on the income in accordance with sections 13(8) to 13(11) of the Income Tax Act (Cap. 34, Revised Edition 2008) (or the same provisions re-enacted in future editions of the Singapore Income Tax Act or have been modified in minor aspects only after the date of signature of this Agreement), the condition of the exemption stated in section 13(9)(b) shall be considered fulfilled notwithstanding that the highest rate of tax levied in Ireland on the gains or profits from any trade or business carried on by a company in Ireland is 12.5%. If, subsequent to the signing of the Agreement, the highest rate of tax levied in Ireland on the gains or profits from any trade or business carried on by a company in Ireland is modified to a rate other than 12.5%, the competent authorities of Singapore and Ireland shall consult each other with a view to determining whether exemption shall continue to be accorded by Singapore.
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