However, where the beneficiary or trustee is a non-Irish resident, only Irish source income arising in such cases is taxable.

types of transaction for funds from international agencies and other foreign sources: international payments direct to all types of institutions (of which: payments for R D expenditure), transfers from international sources to all levels of government; optional: international payments direct to public institutions, international payments direct to private institutions, transfers from international sources to central government, to regional governments and to local governments,

Article 21 TRLIS, entitled ‘Exemption to avoid international double taxation on dividends and income from foreign sources arising from the transfer of securities representing the equity of entities not resident in Spain’, is contained in Chapter IV TRLIS.

In the case of branches of foreign companies, all capital for the initial investment must be provided from foreign sources.Borrowing from local sources is only permitted after the initial implementation of the project, for financing working capital requirements.ESinvestment in Spain by foreign government and foreign public entities (which tends to imply, besides economic, also non-economic interests to entity's part), directly or through companies or other entities controlled directly or indirectly by foreign governments, need prior authorisation by the government.FRforeign purchases exceeding 33,33 % of the shares of capital or voting r ...[+++]ights in existing French enterprise, or 20 % in publicly quoted French companies, are subject to the following regulations:after a period of one month following prior notification, authorisation is tacitly granted for other investments unless the Minister of Economic Affairs has, in exceptional circumstances, exercised its right to postpone the investment.FRforeign participation in newly privatised companies may be limited to a variable amount, determined by the government of France on a case by case basis, of the equity offered to the public.FRfor establishing in certain commercial, industrial or artisanal activities, a specific authorisation is needed if the managing director is not holder of a permanent residence permit.ITexclusive rights may be granted or maintained to newly privatised companies.

In the case of branches of foreign companies, all capital for the initial investment must be provided from foreign sources.

(c) May be vulnerable to pressure from foreign or other sources.