4. Companies in a contracting state whose capital is owned or controlled directly or indirectly by one or more residents of the other contracting state are not subject, in the first contracting state, to a tax or related requirement that is different or more burdensome from the taxation and related requirements to which other similar enterprises of that first state are or may be subject. 3. The imposition of a stable establishment that a firm of one contracting state has in the other contracting state is not perceived less favourably in that other state than the taxation applied to the enterprises of that other state carrying out the same activities. Ireland currently has a double taxation agreement with: 4. The competent authorities of the contracting states communicate directly with each other in order to reach an agreement within the meaning of the previous paragraphs. Where it is desirable to reach agreement on an oral exchange of views, such an exchange of views may take place in a joint committee composed of representatives of the competent authorities of the contracting states. Ireland is in the process of signing comprehensive double taxation agreements with 74 countries, 73 of which are currently in force. There is an outstanding agreement between Ireland and Ghana that has not yet entered into force.

These double taxation agreements include direct taxes which include income tax, general social security contributions, corporation tax and/or capital gains tax in Ireland. 1. Notwithstanding the remedies provided by the national law of those States, where a resident of a contracting state considers that the actions of one or both of the contracting states give rise to an imposition that does not comply with the provisions of this Convention, he may submit his case to the competent authority of the contracting state of which he is domiciled. 3. The competent authorities of the contracting states endeavour to resolve by mutual agreement any difficulty or doubt about the interpretation or application of this convention. They may also agree on the abolition of double taxation in cases not provided for by this convention. This provision should not be construed as requiring one of the States Parties to grant residents of the other State party personal allowances, tax breaks and tax reductions because of marital status or family obligations to their own residents, or to require Ireland to grant Danish residents an exemption or exemption that is eligible under the provisions of the Financing Act (benefits). 1956 (No.

8 of 1956), as amended later, or Part II of the Finance (Miscellaneous Provisions) Act, 1956 (No. 47 of 1956), later amended. The competent authorities of the contracting states exchange this information (i.e. the information available to them according to their respective tax laws as part of a normal administrative procedure) to the extent that it is necessary for the application of the provisions of this Convention or for the prevention of fraud or the administration of legal provisions against evasion with respect to the taxes that are the subject of this Convention. All the information thus exchanged is treated as secret and cannot be disclosed to anyone other than those affected by the taxation and collection of taxes covered by this Convention. No information can be exchanged that would reveal trade, trade, industrial or professional secrets or business procedures. 3. The competent authorities of the contracting states agree on any doubts that arise as to the taxes to which this Convention applies.

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