(1) Income arising to any individual, whether resident in the State or not, from any employment exercised aboard an aircraft -
(a) that is operated in international traffic, and
(b) where the aircraft is so operated by an enterprise that has its place of effective management in the State,
shall be chargeable to tax under Schedule E.
(1A) Subsection (1) shall not apply for the year of assessment 2022 or any subsequent year of assessment where, for that year of assessment an individual -
(a) is not resident in the State,
(b) is resident for the purposes of tax, by virtue of the law of the territory next-mentioned in this paragraph, in a territory with the government of which arrangements are for the time being in force by virtue of section 826(1), and
(c) is subject to tax on the income referred to in subsection (1) in a territory with the government of which arrangements are for the time being in force by virtue of section 826(1).
(2) For the purposes of an arrangement to which this sec
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