Irish Domicile & Residence Rules

The Republic of Ireland would not initially be thought of as a preferred location for fiscal migration given its relatively high personal income tax regime but upon closer inspection it offers non- domiciled but ordinarily resident individuals even better tax saving than available in the UK. The reason is simply that unlike the UK Ireland has not amended its historic domicile and residence laws meaning that a non-domiciled but Irish tax resident individual is only taxed on a remittance basis no matter the duration of their stay in Ireland and further does not have exposure to comparable annual taxes and/or duties that can amount to between £30 to £50k per annum. However, just like the UK, an Irish non-domiciled resident will also fully benefit from the large tax treaty network that Ireland enjoys with many countries around the world and partly goes to explain why Ireland has a significant pool of wealthy (often American) expatriates living within its borders.

Further, unlike the UK it is also possible for individuals to carry out work for a non-Irish firm pursuant to a ‘Service Contract’ and control Irish income tax exposed remuneration as Ireland levies income tax by reference to “where the income really comes to the employee” and not by reference to the place “where the tasks of the employee are performed”. In addition, the Republic of Ireland also enjoys one of the EU’s most competitive corporate tax rates of only 12.5% which, if carefully planned, can be integrated into the fiscal migration plan of the proposed migrant. It should be noted that the SCF Group has its own extensive management centre just outside of Dublin in County Wicklow

For more information on these benefits please contact one of our tax planning consultants.