The fact that the payee of the dividend is not required to pay Irish tax on such dividend
because of the application of reliefs or exemptions under Irish revenue laws does
not prevent the application of the reduction in rate of United States tax with respect
to such dividend. If the dividend would have been subject to Irish tax had the payee thereof derived
an income large enough to require payment of tax then liability to Irish tax exists
for the purpose of the reduction in rate of United States tax. As to what constitutes a permanent establishment, see Article II(1)(i) of the convention.
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