I have a Section 23 type tax shelter which is not "ring fenced" and I use it to shelter my taxable Irish rental income from tax. Now I am considering a property investment in the UK. Most of the rental income from this new UK property will be taxable, as I will have little allowable expenses and a low mortgage.
My questions are:
1) Will I have to pay UK income tax on the taxable rental income which originates in the UK? Yes as the property is UK situate but you may get relief under the Irish/UK double taxation agreement by way of a credit for UK tax paid against the Irish tax due on UK rent under the DTA the UK have taxing rights over a UK property
2) When I calculate my Irish tax (having taken account of the tax already paid in UK, there may be some additional tax payable in Ireland), will my Irish tax shelter be usable to shelter the additional tax payable to the Irish Revenue?