Patrick Costello (Dublin South Central, Green Party)
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331. To ask the Minister for Finance the number of claims for a benefit under the Israel-Ireland double taxation agreement in each of the past five years; the number that required further investigation; the number that were rejected; the number that were rejected in particular due to the fact that the company, person or income to be taxed was based in illegally occupied territories to which the treaty does not apply; and if he will make a statement on the matter. [30658/21]

Paschal Donohoe (Dublin Central, Fine Gael)
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The provisions of the Double Taxation Treaty between Ireland and Israel apply to persons, including companies, who are resident of either Contracting State or both as defined by the Treaty. Benefits under the Treaty are only extended by one State to a resident of the other State and with respect to income arising in either State. Persons not so resident and sources of income not from within either State do not qualify for Treaty benefits.

I am informed by Revenue that all double taxation treaty reliefs or benefits must be in accordance the terms of the relevant Treaty and the Taxes Consolidation Act.

Accordingly, Revenue examines all claims, having regard to relevant supporting information, and where it has reason to reject a claim it does. Where a claim examined by a Revenue Officer does not have sufficient information, documentation, or the appropriate certification from the tax authority of the State of residence of the claimant, it will be rejected and no further investigation is required in such instances.

The total number of claims made pursuant to a benefit of the Ireland-Israel Double Taxation Treaty over the last five years was 697. The total number that were rejected over the same period was 40. No claim was rejected because it related to the occupied territories and the breakdown of the other information for each of the past five years is set out in the table below.

Due to Revenue’s obligation to protect the confidentiality of taxpayer information and in line with Revenue’s statistical disclosure protocol, where there are less than ten cases in a category these are indicated as “<10”.