S.I. No. 468/2014 - Double Taxation Relief (Taxes on Income) (Kingdom of Denmark) Order 2014.

1. This Protocol shall be subject to ratification in accordance with the applicable procedures in Ireland and in the Kingdom of Denmark. The Contracting States shall notify each other in writing, through diplomatic channels, when their respective applicable procedures have been satisfied.

2. The Protocol shall enter into force on the date of the later of the notifications referred to in paragraph 1. The provisions of this Protocol shall have effect with regard to tax years beginning on or after 1 January of the calendar year next following the year of the entry into force of this Protocol.

IN WITNESS WHEREOF the undersigned, duly authorised thereto, have signed this Protocol.

DONE in duplicate at Dublin on 22 July 2014, in the English language.

For the Government of Ireland

For the Government of the Kingdom of Denmark

Simon Harris

Niels Christen Pultz

GIVEN under the Official Seal of the Government,

14 October 2014.

ENDA KENNY,

Taoiseach.

Notice of the making of this Statutory Instrument was published in

“Iris Oifigiúil” of

21

st October

, 2014.

WHEREAS it is enacted by section 826(1) (as amended by

section 157

of the

Finance Act 2010

(No. 5 of 2010)) of the

Taxes Consolidation Act 1997

(No. 39 of 1997) that where the Government by order declare that arrangements specified in the order have been made with the government of any territory outside the State in relation to affording relief from double taxation in respect of income tax, corporation tax in respect of income and chargeable gains, capital gains tax or any taxes of a similar character imposed by the laws of the State or by the laws of that territory and, in the case of taxes of any kind or description imposed by the laws of the State or the laws of that territory, in relation to exchanging information for the purposes of the prevention and detection of tax evasion, granting relief from taxation under the laws of that territory to persons who are resident in the State for the purposes of tax or collecting and recovering tax (including interest, penalties and costs in connection with such tax) for the purpose of the prevention of tax evasion, and that it is expedient that those arrangements should have the force of law, and that the order so made is referred to in Part 1 of Schedule 24A of the

Taxes Consolidation Act 1997

, then, subject to section 826 of that Act, the arrangements shall, notwithstanding any enactment, have the force of law as if such order were an Act of the Oireachtas on and from the date of the insertion of a reference to the order into Part 1 of Schedule 24A;

AND WHEREAS it is further enacted by

section 826

(6) of the

Taxes Consolidation Act 1997

that where such an order is proposed to be made, a draft of the order shall be laid before Dáil Éireann and the order shall not be made until a resolution approving of the draft has been passed by Dáil Éireann;

AND WHEREAS a draft of the following Order has been laid before Dáil Éireann and a resolution approving of the draft has been passed by Dáil Éireann;

NOW, the Government, in exercise of the powers conferred on them by section 826(1) (as amended by

section 157

of the

Finance Act 2010

(No. 5 of 2010)) of the

Taxes Consolidation Act 1997

, hereby order as follows