Elimination of Double Taxation

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..... e allowance as a credit against Indian tax of tax paid in a territory outside India (which shall not affect the general principle hereof), the amount o Irish tax paid, under the laws of Ireland and in accordance with the provisions of this Convention whether directly or by deduction, by a resident of India, in respect of income from sources within Ireland which has been subjected to tax both in In .....

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..... o the same profits, income and gains by reference to which Indian tax is computed. (b) In the case of a dividend paid by a company which is a resident of India to a company which is a resident of Ireland and which controls directly or indirectly 25 per cent or more of the voting power in the company paying the dividend, the credit shall take into account [in addition to any Indian tax creditable u .....

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..... e date of signature of this Convention and that the activities have been carried out within India. (b) The provisions of sub-paragraph (a) shall cease to apply after twelve years from the date o entry into force of this Convention. (c) Should India amend in substance its incentive provisions in relation to the activities specified in sub-paragraph (a) or introduce any new incentive provisions in r .....

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