The Government of the Kingdom of the Netherlands
and
the Government of Ireland,
Desiring to further develop their economic relationship and to enhance their co-operation in tax matters,
Intending to conclude a new Convention for the elimination of double taxation with respect to taxes on income and capital gains without creating opportunities for non-taxation or reduced taxation through tax evasion or avoidance (including through treaty-shopping arrangements aimed at obtaining reliefs provided in this Convention for the indirect benefit of residents of third States),
Have agreed as follows: