(d) Where the natural national of both States Parties or none of them is a national, the competent authorities of the States Parties shall decide by mutual agreement on the matter. 3. Where a person other than a natural person resides in both States Parties pursuant to paragraph 1 below, the competent authorities of the States Parties shall endeavour by mutual agreement to determine in which State Party that person is considered to reside for the sole purposes of the Convention; taking into account the place of actual management, the place where it is registered or otherwise constituted, and all other relevant factors. In the absence of such a convention, that person shall not be entitled to a tax reduction or exemption under this Convention, except to the extent and to the extent that may be agreed upon by the competent authorities of the States Parties. 5 For the purposes of paragraph 3 of Article XXII (Consultation) of the General Convention on Trade in Services, the States Parties agree that, notwithstanding this paragraph, any dispute between them as to whether a measure falls within the scope of this Convention may be submitted to the Council for Trade in Services in accordance with this paragraph, only with the agreement of both States Parties. Doubts as to the interpretation of this paragraph shall be dispelled in accordance with article 25, paragraph 4, or, in the absence of agreement under this procedure, in accordance with another procedure agreed upon by both States Parties. Social security taxes: Individuals are responsible for wage-related social security contributions (PRSI), including a health tax. The calculation of these contributions shall include the determination of the income subject to such a levy, the bands to which the corresponding rates apply and any exemptions applicable. Ireland has a social security agreement with Canada. In certain circumstances, social security contributions paid in Canada may be taken into account in determining entitlement to Irish benefits, such as old age and old age pensions.
Similarly, contributions made in Ireland can be set off against Canadian benefits, including the Canada Pension Plan. 2. Denunciation of this Agreement shall not have the effect of reviving an agreement or arrangement which has been repealed by this Agreement or by agreements previously concluded between the Contracting Governments. Ireland and Canada have a tax treaty with a double taxation treaty that should prevent double taxation of the same income, so it is important to use it. (b) by another agreement concluded by a Contracting State. Double taxation treaties are very useful for people like you who have business interests, property or income in more than one jurisdiction.