On 10 June 2014, officials from Ireland and Botswana signed a tax treaty. The treaty is the first of its kind between the two countries.
The treaty covers Irish income tax, corporation tax, capital gains tax and the universal social charge. It covers Botswana income tax and capital gains tax.
The treaty includes provisions that a service permanent establishment will be deemed constituted if an enterprise of one State furnishes services in the other State through employees or other engaged personnel for the same or connected projects for a period or periods aggregating more than 6 months in any 12 month period.
A service PE will also be deemed constituted when an individual provides professional services or other activities of an independent nature in a contracting state for a period or periods aggregating more than 183 days in any 12 month period.
Both countries use the credit method for the elimination of double taxation.
The treaty will enter into force 30 day after the ratification instruments are exchanged. For Ireland, the treaty will apply from 1 January of the year following its entry into force. For Botswana, the treaty will apply 30 days after its entry into force in regard to withholding taxes, and from 1 July of the year following its entry into force for other tax matters.
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