2. The tax authorities of the Contracting Governments may communicate directly with each other in order to bring into force the provisions of this Agreement and to avoid any difficulty or doubt as to the application or interpretation of the Agreement. 4. Where a company established in either territory receives profits or income from sources within the other territory, the government of that other territory shall not impose any form of taxation of dividends paid by the company to persons not resident in that other territory, or of tax on the undisorended profits of the company; since such dividends or retained earnings constitute all or part of profits or income. (a) the recipient is in the other zone for one or more periods with a total duration of 183 days during the relevant Canadian tax year or fiscal year. during the Irish taxation year and that Canada has entered into tax treaties or arrangements with many countries, commonly known as tax treaties. The main objectives of tax treaties are the prevention of double taxation and the prevention of tax evasion. (a) the agreements set out in the schedule to this Regulation have been entered into with the Government of Canada with respect to the exemption from double taxation in respect of income, non-taxation or corporation tax and all taxes of a similar nature imposed by the laws of the State or by the laws of Canada, and (ii) with respect to other Canadian taxes for fiscal years; beginning on the first day of January of the calendar year following the calendar year in which the instruments of ratification are exchanged. 4. In this Article, “taxation” means the taxes which are the subject of this Agreement. 3.
The Convention between the Government of Ireland and the Government of Canada, signed at Ottawa on 28 October 1954, for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, shall terminate and expire for any period for which this Convention takes effect in accordance with paragraph 2 of this Article. To the extent that a life insurance company established in Canada has a permanent establishment in Ireland, this paragraph shall not affect any of the provisions of Irish law relating to the taxation of income from the capital of life insurance companies established outside Ireland, .m. to the extent that they have not become inoperative by Article III, paragraph 2 of the Agreement. between the Government of Ireland and the Government of Canada for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion on Income, signed at Ottawa on October 28, 1954), were in force on the day of signature of this Convention. However, the above reservation shall not be considered to have the consequence that the above-mentioned provisions of Irish law derogated from the provisions laid down or had been regarded as such by the Oireachtas. CONSIDERING that, pursuant to section 361 (1) of the Income Tax Act 1967 (No. 6 of 1967) that, where the Government declares by decision that agreements have been concluded with the Government of a territory outside the State for the purpose of granting exemption from double taxation with respect to income tax, income tax or corporation tax and all similar taxes imposed by the laws of the State or by the laws of that territory and that it is appropriate: Whether such agreements have the force of law, agreements, notwithstanding anything in a decree, shall have the force of law: 2. . . .