Dáil Éireann Debate, Tuesday - 13 January 2026
824. Deputy Pearse Doherty asked the Tánaiste and Minister for Finance further to Parliamentary Question No. 252 of 20 March 2025, the reason Jersey does not appear on the list of double taxation agreements; if other jurisdictions have not been included; and if he will make a statement on the matter. [74056/25]
Amharc ar fhreagraTax treaties provide greater certainty and fairness for taxpayers regarding their tax obligations in foreign jurisdictions, and they are key to the prevention of double taxation. It is Ireland's policy to treat negotiations for tax treaties as confidential until they are signed, at which point they are published on Revenue's website. This is standard practice for most jurisdictions.
Ireland has signed 78 comprehensive double taxation treaties, 75 of which are in effect*: inance.cloud.gov.ie/apps/eDocs/s/F585/Files/F585-007-2019/2025/260112%2074056-25%20PQ%20REF.docx#_ftn1
Ireland has tax treaties with all EU Member States and all OECD member countries, bar the two newest members (Colombia and Costa Rica).
The text of each of Ireland’s double taxation treaties is available at: www.revenue.ie/en/tax-professionals/tax-agreements/double-taxation-treaties/tax-treaties-by-country.aspx, with the dates of effect of those treaties available at: www.revenue.ie/en/tax-professionals/tax-agreements/dates-of-effect/index.aspx
Jersey are not included on this list as the agreements in place between Ireland and Jersey do not represent a comprehensive double taxation treaty but rather include a Tax Information Exchange Agreements (TIEA) alongside what is referred to as a “Limited Scope Agreement”.
Ireland is committed to the full exchange of tax information and, in addition to its extensive comprehensive tax treaty network, Ireland has concluded Tax Information Exchange Agreements (TIEAs) with 26 countries and autonomous regions, all of which are in effect. The TIEAs concluded by Ireland are based on the OECD model TIEA which grew out of the work undertaken by the OECD to address harmful tax practices globally and represents the international standard for effective exchange of information in tax matters.
Ireland’s list of TIEAs is published at: www.revenue.ie/en/tax-professionals/tax-agreements/tiea/index.aspx?page=g
Among the 26, is an agreement with Jersey.
In parallel with the conclusion of the TIEA, it was also recognised that taxation obstacles may, in certain circumstances, hinder trade and the free movement of individuals between Ireland and Jersey. Accordingly, alongside the TIEA, an agreement for ‘affording relief from double taxation with respect to certain income of individuals and establishing a mutual agreement procedure in connection with the adjustment of profits of associated enterprises’ was also entered into with Jersey (this type of an agreement, which is not a comprehensive double taxation treaty and is often referred to as a “Limited Scope Agreement” as outlined above).
This Agreement is, as stated, limited in scope and prevents double taxation of certain sources of income of individuals, in particular, pensions from past employment, salaries and pensions of government employees, and income of students. There is also a provision in the Limited Scope Agreement with Jersey to allow both countries to resolve cases of potential double taxation arising from the adjustment of profits of companies by way of a mutual agreement procedure.
However, provisions in respect of immovable property, business profits, dividends, interest, royalties, capital gains, income from employment, directors’ fees, etc. are absent from all Limited Scope Agreements.
The Limited Scope Agreement with Jersey was approved by the Oireachtas in 2009. The text of the Limited Scope Agreement with Jersey is available at: www.revenue.ie/en/tax-professionals/tax-agreements/tiea/index.aspx?page=j, alongside the TIEAs.
Subsequently, and in order to incorporate the tax treaty-related minimum standards, agreed as part of the G20/OECD Base Erosion and Profit Shifting (BEPS) project, into the Limited Scope Agreements, including the one with Jersey, Protocols to the Agreements were negotiated between the parties to include the necessary BEPs related modifications. The Protocol with Jersey was approved by the Oireachtas in 2024.
Jersey, Guernsey and the Isle of Man are the only regions with which Ireland has entered into such Limited Scope Agreements.
*Treaties with Ghana, Kenya and Liechtenstein have yet to be ratified.
