Pearse Doherty (Donegal, Sinn Fein)
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89. To ask the Minister for Finance if the payment of a domicile levy here enables a person to claim exemption from tax liability in the United States of America under the double taxation clauses in the 1997 treaty between the two countries; and if he will make a statement on the matter. [18315/16]

Pearse Doherty (Donegal, Sinn Fein)
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90. To ask the Minister for Finance the number of cases in which Irish persons have attempted to claim exemption from foreign taxation on the basis that they have paid the domicile levy here; and if he will make a statement on the matter. [18316/16]

Michael Noonan (Limerick City, Fine Gael)
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I propose to take Questions Nos. 89 and 90 together.

I am informed by Revenue that the Irish taxes covered by the Ireland/United States double taxation treaty 1997 are income tax, corporation tax and capital gains tax and any identical or substantially similar taxes imposed after the date of signature of the treaty. This is provided for in Article 2 of the treaty, which deals with taxes covered. I am further informed that it has been the view of Revenue, since its introduction in 2010, that the domicile levy could not be regarded as a tax covered by that treaty. I am further informed that Revenue does not maintain a record of the number of cases, to the extent that such exist, of attempted claims to exemption from foreign taxation on the basis that the domicile levy has been paid in Ireland.