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Change in Remittance basis of income tax in Ireland

The basis of assessment for Irish resident but non-domiciled and Irish resident but not ordinarily resident taxpayers in Ireland has changed under recent legislation.

Previously such taxpayers were only taxable in Ireland on Irish income and worldwide income remitted to Ireland. They were also fully taxable on all UK income.

The changes in Finance Act 2008 mean that the remittance basis has been extended to UK income including investment income and employment income but excluding employment which relates to duties performed in Ireland.

In summary the remittance basis of taxation applies in Ireland to:

  • Irish resident and non-domiciled taxpayers
  • Irish resident, Irish domiciled and non-ordinarily resident taxpayers

    There is no need to elect for the remittance basis of tax in Ireland, or to make a annual payment for being resident but non domiciled in Ireland.

    This contrasts favourably to recent legislation in the UK which has placed an increased burden on non-domiciled but UK resident taxpayers and provides some tax planning opportunites in some specific cases.

    Contributed by: Edward Murphy
    Crowleys DFK, Dublin & Cork
    November 2008


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