Competent Authority Agreement Between Ireland and The United States Concerning the Treatment of Common Contractual Funds (“CCF”) Under the Ireland-United States Double Taxation Convention

The Competent Authorities of Ireland and the United States have entered into an agreement concerning the treatment of Common Contractual Funds (“CCF”) under the Ireland-United States Double Taxation Convention.

This agreement was entered into at the request of Ireland in order to clarify the transparent nature of the CCF and in order to preserve the entitlement to benefits under the Convention of Irish resident unit holders in a CCF.

It had come to the attention of the Competent Authorities that difficulties could have arisen concerning the application of the Convention to income received by Irish unit holders in a CCF. This resulted from the provisions of subparagraph 1(d) of Article 4 of the Convention and Article 1 of the Protocol to the Convention.

The Competent Authorities have agreed that in order to reach the result intended by the Contracting States, a CCF will not be regarded as a resident of Ireland for the purposes of Article 4. Accordingly, under the first sentence of Article 1 of the Protocol, a unit holder in a CCF will be entitled to benefits under the Convention, provided the unit holder is a resident of Ireland that satisfies the requirements of Article 23 (Limitation on Benefits).

Click on the following link for the text of the Agreement: http://www.revenue.ie/en/practitioner/law/double/usaprot.html

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