Ireland: residence, domicile and remittance basis, corporate taxation

Ireland distinguishes three notions that are often confused: residence, assessed each year on the basis of presence; ordinary residence, which is acquired and lost slowly; and domicile, a general-law notion that follows the intention to settle permanently. It is domicile, not nationality, that opens access to the remittance basis: a non-domiciled resident is taxed on foreign income and gains only if they remit them.

For businesses, the country applies a standard rate of 12.5%¹ to trading income, but a rate of 25%² to non-trading income. The low rate therefore rewards genuine activity, not the mere holding of investments.

The seconded employee has a dedicated regime, the SARP, extended for arrivals up to 2030 but tightened for those occurring from 2026.

Residence, ordinary residence and domicile

A person is Irish tax resident for a tax year — which follows the calendar year — if they are present in Ireland for at least from 183 days³ in the year, or at least from 280 days⁴ when combining the current year and the previous one. A year in which presence does not exceed up to 30 days⁵ does not count towards the combined total (Revenue, How to know if you are resident for tax purposes).

Ordinary residence follows a logic of duration. According to the Revenue manual, a person who has been resident for 3 years⁶ in a row becomes ordinarily resident at the start of the following year; conversely, they cease to be so only after 3 years⁷ in a row of non-residence (Tax and Duty Manual, Part 34-00-01).

Domicile is a general-law notion, more stable than residence: in essence, it designates the country where one lives with the intention of remaining permanently. Everyone receives a domicile of origin at birth, generally that of the father, and keeps it until acquiring another, which requires clear evidence (Revenue, What is domicile).

Practical consequence: a foreign nationality is not enough to establish non-domiciled status. What matters is the domicile of origin and the absence of any intention to settle in Ireland forever. A French person born and domiciled in France who moves to Dublin remains, in principle, non-domiciled; a foreign national born to a father domiciled in Ireland may, on the contrary, be domiciled in Ireland. The Revenue texts read do not lay down any rule based on nationality.

The remittance basis: what it covers, what it does not

The remittance basis applies to foreign-source income and foreign capital gains of a resident but non-domiciled person: such income and gains are taxable only to the extent that they are remitted to Ireland. Amounts left abroad are not taxed; amounts transferred are taxed in the year of transfer.

• Employment income: the remittance basis does not apply to income from an employment of non-Irish source for the part that remunerates duties performed in Ireland. This income is taxed, whether remitted or not. What matters is not the place of payment but the place where the duties are performed.
• Capital gains: gains on foreign assets follow the remittance rule; gains on Irish assets are taxed normally. Gains on specified Irish assets (land, buildings and mineral rights located in Ireland) are taxable even for a non-resident.
• Irish-source income (dividends from Irish companies, Irish rents, Irish interest): always taxed, regardless of domicile.
• SARP: the remittance basis does not apply to income from the employment covered by the SARP, according to the Revenue manual dedicated to this regime.

The management of foreign accounts therefore becomes a tax issue: mixing foreign income, capital predating arrival and gains in a single account, then remitting, makes it difficult to demonstrate the nature of the amounts transferred.

The detailed rules for identifying the amounts remitted (order of allocation of a mixed account, indirect transfers, use of a foreign card in Ireland) were not found in an official source read: they must be checked in the Revenue manual on section 71 of the Taxes Consolidation Act before organising any transfers.

Tax scale and social charges

Income tax has two rates. For a single person without dependent children in 2026, the first €44,000⁸ are taxed at 20%⁹ and the remainder at 40%¹⁰ (Revenue, tax rates and rate bands). To this are added the universal social charge (USC) and PRSI contributions, which bring the marginal burden well above the higher rate.

The standard USC and PRSI rates and bands for 2026 could not be read on the Revenue page that publishes them: they are not reproduced here.

Investment income, capital gains and inheritances

Dividends paid by an Irish company bear withholding tax (DWT) of 25%¹¹, which is creditable: the gross dividend remains taxed at the marginal rate, with USC and PRSI. Foreign dividends are also taxed at the marginal rate for the domiciled resident (Revenue, Dividend Income).

Revenue indicates a CGT rate of 31%¹² for most gains, on a page updated at the end of October 2026 (Revenue, Capital Gains Tax). This is a reduction decided in the 2027 budget: the previous rate was figure being updated, which would remain applicable to building land according to a law firm's summary. The effective date given by that firm, 7 October 2026, must be confirmed by the Finance Act.

Gifts and inheritances fall under CAT, at a rate of 33%¹⁴ above the allowances by family group (Revenue, CAT rates).

CAT group thresholds, the annual CGT exemption and the CAT connecting-factor rules for a non-domiciled person (in particular the rule on prior years of residence) have not been verified in any source consulted.

Special regime for seconded employees: SARP

SARP exempts from income tax a portion of the salary of an executive assigned to Ireland by their employer. For arrivals from 2026, it applies to 30%¹⁵ of income between from €125,000¹⁶ and up to €1,000,000¹⁷; for arrivals in 2023 to 2025, the lower threshold was figure being updated.

• basic salary of at least from €125,000¹⁶, excluding bonuses and share-based remuneration;
• prior employment outside Ireland within the group for at least from 6 months¹⁹;
• duties performed in Ireland for at least from 12 months²⁰;
• no Irish residence during the from 5 years²¹ preceding arrival;
• certification by the employer within up to 180 days²² of arrival (arrivals from 2026).

The relief lasts for a maximum of up to 5 years²³ consecutive (Revenue, SARP manual). For arrivals from 2026, the year of arrival does not qualify for the relief (Revenue, SARP conditions).

Two rates depending on the nature of the income

The standard rate of 12.5%¹ has applied since 2003 to commercial income (trading income). Section 21A, by contrast, subjects non-trading income — investment income, rents, interest — as well as certain listed activities to the rate of 25%² (Revenue, Tax and Duty Manual 02-02-02).

The boundary between trading income and passive income is therefore the decisive point: a consulting company that invoices clients using staff and resources in Ireland may fall under the standard rate; a personal holding company, or a company that collects royalties without any real activity, falls under the higher rate. Substance — staff, decision-making, resources — is not a formality.

A distribution to an individual shareholder triggers DWT of 25%¹¹; for a resident shareholder, the gross dividend is then taxed at the progressive scale, together with USC and PRSI. The combination of low corporate tax and heavy personal taxation of dividends often makes retaining profits in the company more logical than distributing them.

The rules on company residence (incorporation, effective management), the Knowledge Development Box regime, the surcharges on close companies (close company surcharge) and the preliminary tax thresholds have not been identified in any official source consulted.

Minimum tax for large groups

Ireland has transposed Pillar Two in Part 4A of the Taxes Consolidation Act: multinational groups and large domestic groups must bear a minimum rate of 15%²⁴ (Revenue, Pillar Two). The regime applies only to groups whose consolidated turnover reaches from €750,000,000²⁵ in at least two of the four preceding financial years (Part 4A guidance notes).

For an SME, an entrepreneur's company or a family holding company below this threshold, Pillar Two has no effect: the applicable rate remains that of corporation tax.

A French national, like any Union citizen, can settle in Ireland without a residence permit. Ireland is not, however, a member of the Schengen area: identity checks at borders remain, and the Common Travel Area with the United Kingdom follows its own rules.

The immigration routes for third-country nationals (Critical Skills Employment Permit, permission for persons with financial resources, the investment programme now closed) have not been verified in any official source consulted for this page.

Arrival and departure do not take effect at the same pace. Residence is acquired from the first year in which one of the presence tests is met; ordinary residence comes only after a series of years; domicile, for its part, may never change.

On departure, a person who remains ordinarily resident is taxed as a resident, except in particular on income from an employment exercised entirely outside Ireland and on other foreign income not exceeding up to €3,810²⁶ over the year. They also remain taxable on their worldwide capital gains for as long as ordinary residence lasts (Revenue manual).

A significant disposal made in the year following departure therefore does not necessarily escape Irish tax: before selling, it is necessary to check the effect of the tax treaty between Ireland and the new country of residence, which may allocate the right to tax differently.

Finally, domicile may have an effect independent of residence: a person domiciled in Ireland whose worldwide income exceeds more than €1,000,000²⁷, whose Irish property exceeds more than €5,000,000²⁸ and whose Irish income tax is less than less than €200,000²⁹ may owe a domicile levy of €200,000³⁰ (Revenue, domicile levy).

No documented official source on the cost of living for an expatriate or on property prices was consulted for this page. Housing in Dublin is reputed to be the largest item of expenditure; this point must be quantified using the Irish statistical office (CSO) series or price registers before any decision is made.

1. Document the domicile of origin before arrival: place of birth, father's domicile, lasting ties abroad, intention to leave.
2. Separate foreign accounts before settling: prior capital, foreign income and disposal proceeds in distinct accounts.
3. For a seconded employee, have SARP certified by the employer within the deadline and check the basic salary against the threshold.
4. For a company, document the trading nature of the activity and the substance in Ireland before applying the standard rate.
5. Before a departure, list the disposals planned during the period of residual ordinary residence.

• The remittance basis is not an exemption: it defers tax until the funds are remitted, and covers neither employment exercised in Ireland nor Irish property.
• The rate of 12.5%¹ is not a general rate: it presupposes trading income.
• The reduction in the CGT rate is very recent; its effective date and its exceptions must be read in the finance act.

Is my French nationality enough to make me non-domiciled in Ireland?

No. Domicile does not depend on nationality but on the domicile of origin and on the intention to settle permanently. A French person born and domiciled in France in principle keeps a French domicile when settling in Ireland, but it is up to them to be able to demonstrate it.

Is my salary paid by a foreign company covered by the remittance basis?

Not for the part that remunerates days worked in Ireland: that income is taxable whether or not it is remitted. Only the part corresponding to duties performed outside Ireland can fall under the remittance rule.

Are my gains on foreign shares taxed?

For a resident non-domiciled person, only if the disposal proceeds are remitted to Ireland. For a resident domiciled person, they are taxed in all cases, at the rate of 31%¹² for most gains.

Does an Irish company holding investments benefit from the low rate?

No: non-trading income is taxed at 25%². The standard rate is reserved for income from a genuine trading activity.

Does the global minimum tax concern my company?

Only if it belongs to a group whose consolidated turnover reaches from €750,000,000²⁵ in at least two of the four preceding financial years.