Have you gents seen this one? Hot off the Irish Revenue Commissioners presses via the 2011 Finance Bill:
Tax treatment of flight crew in international traffic.
SECTION 16
36. In page 37, before section 16, to insert the following new section:
The Principal Act is amended in Chapter 5 of Part 5 by inserting the following
section after section 127
127B ( 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
(2} For the purposes of an arrangement to which this section and section
826 applies. 'international traffic' , in relation to an aircraft, does not include
an aircraft operated solely between places in another state "
An tAaire Airgeadais
It basically provides that staff working on board aircraft that owned by an Irish company are liable to Irish tax REGARDLESS OF WHERE THEY ARE RESIDENT AND WHERE THEY EXERCISE THEIR DUTIES.
In other works, a German working for an Irish Airline who lives in Germany and flies from Germany to the US only might now be properly liable to Irish tax - even though he never sets foot in Ireland. Of course the various Double Tax Treaties might have something to say about this.