Elimination of Double Taxation

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....ia regarding the 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....

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.... Irish tax computed by reference to 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 ac....

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....tive provisions remain in substance unchanged since the 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-....