Ireland: corporate tax guide

What the tax system covers

Irish-resident companies are generally taxed on worldwide profits. Trading and nontrading income have different rate rules, while foreign distributions and establishments may have specific relief or exemption conditions.

When a company becomes tax resident

An Irish-incorporated company is generally Irish tax resident unless a tax treaty treats it as resident elsewhere. A foreign-incorporated company can be resident through central management and control in Ireland. Revenue’s analysis considers where policy, investment decisions and major contracts are determined, alongside the broader management facts. A founder moving to Ireland should assess the company before continuing to direct it from an Irish home.

Rates and the tax base

12.5% trading; 25% nontrading. Classification of trading activity is material. The global minimum-tax framework for in-scope groups is a separate calculation and should not be inferred from these ordinary headline rates.

Outbound dividends, interest and royalties

Dividends: 25% before exemptions. Irish resident companies ordinarily deduct 25% DWT. Qualifying nonresident recipients can claim domestic exemptions with the required declarations; residence in a treaty country alone does not replace the paperwork.

Interest: 20% covered yearly interest; broad exemptions. Covered yearly interest is subject to deduction at the standard income-tax rate. Statutory company-recipient, quoted-debt and other exclusions mean many commercial payments are exempt; verify the exact conditions and paperwork.

Royalties: 20% covered patent royalties; exemptions available. The withholding framework covers patent royalties and other annual-payment categories; it is not a universal tax on every rights payment. Domestic exceptions, administrative treatment and treaty relief must be checked against the actual contract.

Corporate exit tax is distinct from a shareholder moving

Ireland’s corporate exit-tax framework can deem a disposal when a company migrates residence or transfers assets so that Ireland loses taxing rights. The ordinary exit-tax rate is 12.5%; an anti-avoidance rule can substitute the general capital-gains rate where the migration forms part of a disposal arrangement designed to obtain the lower rate. Eligible companies can elect payment in equal instalments over five years, subject to the rules.

The rules contain exclusions where Ireland retains taxing rights and for specified temporary transfers. They should not be presented as a general deemed disposal of every private asset whenever an individual emigrates. A shareholder’s move and a company’s migration are separate events. Identify the owner of each asset, the continuing Irish permanent establishment, the functions moving abroad and the necessary valuations before implementing the operational change.

Foreign companies and income attribution

Irish corporate CFC rules attribute relevant undistributed income to a controlling or connected Irish company where relevant Irish activities occur.

Departure, migration and continuing obligations

Corporate exit tax ordinarily applies at 12.5% on relevant unrealised gains, with an anti-avoidance rule and conditional five-year instalments. Personal ordinary residence can continue for three tax years; this is a separate mechanism.