Heads of the Ultimate Financial Settlement between the British government and the government of the Irish Free State

1. The Government of the Irish Free State undertake to pay to the British Government at agreed intervals the full amount of the annuities accruing due from time to time under the Irish Land Acts, 1891-1909, without any deduction whatsoever whether on account of Income Tax or otherwise.

2. The Government of the Irish Free State agree to pay to the British Government prior to March 31st 1926, the sum of approximately £550,000, being the amount hitherto withheld by them in respect of income tax on annuities payable under the above-mentioned Acts.

3. The British Government accept liability for the provision out of monies provided by Parliament of the cost of the interest and sinking fund on bonus and excess stock under the above-mentioned Acts subject to a contribution by the Irish Free State Government of the sum of £160,000 in the year 1926-27 and at the rate of £134,500 per annum thereafter.

4. It is agreed between the two Governments that the question of double income tax shall be settled generally on the residence basis as elaborated in the scheme which has already been provisionally agreed between the Revenue Departments of the two Governments. The two Governments agree to promote any legislation necessary for this purpose to take effect from the beginning of the financial year 1926-27.

5. The Irish Free State Government agree to discharge their liability outstanding on 1st April, 1926, in respect of the Local Loans Fund by the payment of an annuity payable half-yearly of £600,000 to the Fund for a period of 20 years payable on the 1st January and the 1st July in each year, the first half-yearly payment being payable on the 1st July, 1926.

6. Subject to the provisions of this Agreement the British Government undertake to make no further claim in respect of any portion of the value of property taken over by the Irish Free State belonging to British Government Departments whose administration and powers were under Article 9 of the Provisional Government (Transfer of Functions) Order in Council of 1st April, 1922, excluded from transfer to the Irish Free State Government.Provided that

(a) This paragraph shall not be held to affect the position in regard to the Kilmainham Hospital, the Royal Hibernian School and the Tully Stud Farm.

(b) Nothing in this paragraph shall prejudice the right of the British Government to be indemnified under paragraph 8 of the despatch from the Colonial Office of the 13th October, 1924.¹

7. The Irish Free State Government agree to pay to the British Government the sum of £275,000 in full and final discharge of all claims made to the Compensation (Ireland) Commission in respect of damage done prior to July 11th, 1921, to property belonging to any of the British Government Departments mentioned in the last preceding paragraph:

Provided that this paragraph shall not be held to affect the liability of the Irish Free State Government to satisfy awards of the Compensation (Ireland) Commission made in respect of claims preferred by British Government Departments on behalf of private individuals or the Government of Northern Ireland.

8. The British Government waive all claims against the Government of the Irish Free State for the refund of any portion of the sums paid by them under Section 1 of the Irish Railways (Settlement of Claims) Act, 1921.

9. The Government of the Irish Free State agree to pay to the British Government so much of the deficit of the Unemployment Fund of the United Kingdom as may be attributable to the Irish Free State on the basis of the relative proportions of the insured populations of the two countries as at 31st March, 1922, with interest thereon from that date.

10. The Irish Free State Government agree to make no claim in respect of any of the assets of the Consolidated Fund of the United Kingdom including inter alia the Civil Contingency Fund and receipts on account of Reparations and Inter-Allied Debts.

11. The Irish Free State Government agree to repay to the British Government 75 per cent. of the pensions and compensation allowances payable to ex-members of the Royal Irish Constabulary under the Constabulary Acts, subject to the exception mentioned in Article 10 of the Articles of Agreement for a Treaty between Great Britain and Ireland.

12. For the purposes of any previous agreements between the two Governments, this Agreement shall be deemed to be the ultimate financial settlement mentioned therein.