Ireland, Republic of
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Executive and immigration contacts
Michael Rooney
Sarah Connellan
Rachel Dillion
Marie Caulfield
Elaine O’Gara
Sinead Langan
+353 (1) 221-2857
Email: michael.rooney@ie.ey.com
+353 (1) 221-1514
Email: sarah.connellan@ie.ey.com
+353 (1) 221-2554
Email: rachel.dillion@ie.ey.com
+353 (1) 221-1416
Email: marie.caulfield@ie.ey.com
+353 (1) 475-0555
Email: elaine.ogara@ie.ey.com
+353 (1) 221-2443 (Immigration)
Aislinn Stanton
Email: sinead.langan@ie.ey.com
+353 (1) 221-1602 (Immigration)
Email: aislinn.stanton@ie.ey.com
Gillian Moore
+353 (51) 847-900 (resident in Waterford)
Peter O’Connor
Email: gillian.moore@ie.ey.com
+353 (21) 480-2843 (resident in Cork)
Colin Spence
Jennifer Sweeney
Jake Higgitt
Gareth Carroll
Private Client Services contact
Alison McHugh
Email: peter.oconnor@ie.ey.com
+ 353 (1) 221-1240
Email: colin.spence@ie.ey.com
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Email: jennifer.sweeney1@ie.ey.com
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Email: jake.higgitt@ie.ey.com
+353 (1) 221-2475
Email: gareth.carroll@ie.ey.com
+353 (1) 221 2180
Email: alison.mchugh@ie.ey.com
The rules regarding work permits and self-employment discussed in Section G of this chapter are regularly changed. Because of these changes, readers should obtain updated information before engaging in transactions.
A. Income tax
Who is liable. Income tax liability in Ireland depends on an individual’s tax residence and domicile.
The tax year is the calendar year. For the 2024 tax year, an individual is regarded as an Irish tax resident if he or she meets any of the following conditions:
• He or she spends 183 or more days in Ireland during the period from 1 January 2024 to 31 December 2024.
Chile
China Mainland
Colombia
Kenya
Korea (South)
Kuwait
Congo Malaysia
Senegal
Singapore
South Africa
Tanzania (Democratic Mexico
Thailand Republic of)
Nigeria
United Arab
Egypt Oman Emirates
Ghana
Pakistan
Vietnam
The relief reduces the income tax liability of the relevant individual by allowing a deduction of up to EUR35,000 against employment income. It is claimed through the annual tax return. To qualify for the relief, the individual must spend 30 (previously 40) qualifying days in a tax year or in a continuous 12-month period in the relevant countries. To count as a qualifying day, a day must be one of three consecutive days throughout which the individual is working in the relevant countries. Days spent traveling to and from the work location count as qualifying days for the purposes of the relief. The deduction does not apply to employees paid out of state revenue, such as civil servants, Gardaí (members of the Irish state police) and similar employees.
Income subject to tax. The taxation of various types of income is described below.
Employment income. Most payments made by an employer, including salary, bonuses, benefits in kind, certain equity income and expense allowances, are subject to income tax.
In general, noncash benefits are taxable and are valued at the cost incurred by an employer in providing the benefits. However, special measures govern the valuation of the following taxable benefits:
• Car: The assessable benefit is up to 37.5% of the original market value of the car. The assessable benefit is determined by reference to business mileage and the vehicle’s CO2 emissions. The taxable benefit is reduced if the employee makes a financial contribution to the employer.
• Loans: 13.5% of the amount of the loan, with a reduction for interest paid by the employee. The rate is 4% for a home loan.
• Housing: The annual market value of the rent (the amount a landlord would charge an unconnected tenant to use the property) plus utilities paid by the company (employer-owned accommodation) or rent plus utilities paid by the company (accommodation not owned by the employer).
Employee benefits that are incurred wholly, exclusively and necessarily in the performance of employment duties, are not taxable. Travel expenses from home to work and from work to home may be an exception to this rule.
Education allowances provided by employers to their employees’ children 18 years of age and under are taxable for income tax and social security tax purposes.
Employers must withhold Pay Related Social Insurance (PRSI; see Section C) and the USC (see Section B) and apply the PAYE system (see Section D) with respect to the value of benefits in kind provided to employees during the tax year. Employers’ PRSI
at a rate of 11.15% also applies to any benefits provided to employees.
In general, nonresidents are subject to income tax on employment income, regardless of their domicile, if their duties are carried on and if their salary is paid in Ireland.
Self-employment and business income. Individuals resident in Ireland are subject to tax on income from trades and professions carried on in Ireland and abroad. Nonresidents are taxed on income from trades and professions carried on in Ireland only.
Taxable profits normally consist of net business profits as disclosed in the financial accounts and adjusted to account for deductions not allowed or restricted by tax legislation.
Except for years when a business begins or terminates, taxable profits generally are those for the tax year ending 31 December or for the 12-month accounting period ending in that year.
Investment income. An individual resident and domiciled in Ireland is taxed on worldwide dividend and interest income. If resident but not domiciled, an individual is taxed on all investment income arising in Ireland and on income remitted to Ireland from other countries. A credit for foreign taxes paid may be available if a double tax treaty applies. A nonresident and not domiciled individual is taxed on Irish-source income only.
Dividends received by individuals from Irish tax-resident companies are taxed in full, subject to relief being available under a relevant double tax treaty. Dividends may be subject to withholding tax at a rate of 25%, which is creditable against a resident individual’s income tax liability.
Interest on Irish government securities is subject to income tax and is generally not taxed at source, but may not be taxable if received by nonresident individuals.
Interest credited on or after 1 January 2020 on most bank and building society deposits is taxed at source at a rate of 33%, unless it is paid or credited to nonresidents. A credit is given for tax withheld if the person is taxed on the interest. The final income tax on deposit interest taxed at source is 33%.
Losses from Irish rental properties may be offset against other Irish-source rental income or may be carried forward indefinitely and offset against rental income in future years.
Nonresidents are subject to a 20% withholding tax on nonexempt interest, royalties and rental income.
Directors’ fees. Directors’ fees paid by companies incorporated in Ireland are taxable in Ireland, regardless of the tax residence of the director or the place where duties are performed. Directors’ fees paid by non-Irish companies to Irish residents are taxable in Ireland (however, a relevant tax treaty may override the Irish domestic legislation on when directors’ fees are taxable). Nondomiciled individuals do not pay tax on directors’ fees received from foreign companies if all of the duties are performed outside Ireland unless that income is remitted to Ireland.
expenses incurred by employees are granted only for exceptional items, including purchases of protective clothing.
Personal credits and allowances. The principal credits for the 2024 tax year are listed in the following table. Credits are deducted from the individual’s income tax liability.
* The relief with respect to premiums is restricted to EUR1,000 per adult policy and EUR500 per child policy.
The principal allowances for the 2024 tax year are listed in the following table. Allowances reduce the amount of income of the individual that is taxable at the top income tax rate.
Allowance at top rate
Pension contributions to Varies from 15% to 40% approved schemes (a)(b) of earnings, depending on age of individual
Employment and Investment Incentive
EUR250,000/EUR500,000 (c)
Startup relief for entrepreneurs EUR100,000 (d) Employee Approved Profit Sharing Scheme EUR12,700
(a) Effective from 1 January 2014, the maximum allowable pension fund for tax purposes is set at EUR2 million. Higher thresholds may apply if the value of the pension fund, as of 1 January 2014, exceeds EUR2 million, but does not exceed EUR2,300,000. Any excess is subject to a one-off charge of 40% on drawdown. This limit is set to increase from 2026.
(b) Pension contributions are subject to an earnings cap of EUR115,000.
(c) The allowance is EUR250,000 for a minimum four-year holding period and EUR500,000 for a minimum seven-year holding period.
(d) The allowance can be used to reduce taxable income in one or more of the preceding six tax years.
In general, a nonresident is not entitled to tax credits or personal allowances, but exceptions may apply under Irish income tax law or the provisions of a double tax treaty.
Business deductions and capital allowances. Expenses incurred wholly and exclusively for the purposes of a trade or profession are generally deductible. Deductions for automobile expenses are restricted.
Rates. The following table presents the 2024 income tax rates for single or widowed individuals, or a surviving civil partner.
The following are the 2024 income tax rates for a married couple or civil partners (jointly assessed).
* If both spouses or civil partners have income, married couples or civil partners may have more of their income taxed at the 20% rate. The income bracket is increased by EUR1 for every EUR1 received by the other spouse or civil partner, up to a maximum additional EUR33,000. Consequently, for a married couple or civil partners, the maximum amount of taxable income potentially subject to the 20% rate is EUR84,000.
Nonresidents are taxed at the same rates as residents.
Relief for losses. A loss arising from a trade or profession, as calculated for income tax purposes, may be offset against all income for the tax year in which the loss is incurred, or may be carried forward indefinitely and offset against income from the same trade or profession in future years; however, the loss must be used as early as possible in the years when a profit arises. A loss incurred in the final 12 months of a trade or profession may be carried back and offset against profits from the same trade or profession for the three tax years prior to the year of cessation.
B. Other taxes
Universal Social Charge. The Universal Social Charge (USC) is charged at the following rates and income thresholds.
(a) This income is exempt if income does not exceed EUR13,000.
(b) The 11% rate applies to “relevant income,” excluding employment income that exceeds EUR100,000. Consequently, the 8% rate applies to employment income exceeding EUR100,000.
The USC applies to all income, including noncash benefits-inkind and equity compensation under an unapproved scheme, subject to certain exceptions. It applies to all income before relief for pension contributions and deductions for capital allowances. Chargeable persons are required to pay the USC as part of preliminary tax (see Section D). Employers deduct the USC from payments to employees at the rates shown above.
Inheritance and gift tax. Capital Acquisitions Tax (CAT) includes both gift and inheritance tax and is primarily payable by the beneficiary of a gift or an inheritance.
CAT is payable if any of the following conditions are met:
• The disponer is resident or ordinarily resident in Ireland. If the disponer is not domiciled in Ireland, he or she is not regarded as resident or ordinarily resident for CAT purposes unless he or she has been resident in Ireland for five consecutive years immediately preceding the year of the gift or inheritance.
• The beneficiary is resident or ordinarily resident in Ireland. If the beneficiary is not domiciled in Ireland, he or she is not regarded as resident or ordinarily resident for CAT purposes unless he or she has been resident in Ireland for five consecutive years immediately preceding the year of the gift or inheritance.
• The gift or inheritance consists of Irish property.
CAT is imposed at a rate of 33% for gifts and inheritances received on or after 6 December 2012. It is payable on the amount exceeding the relevant tax-free threshold. Three tax-free thresholds exist. The thresholds vary depending on the relationship between the disponer and the beneficiary. The following are the relevant thresholds.
Threshold When Group EUR applicable
A 335,000
B 32,500
C 16,250
If the beneficiary is a child (including certain foster children), or minor child of a deceased child of the disponer; parents also fall within this threshold if they receive an inheritance from a child
If the beneficiary is a brother, sister, niece, nephew or lineal ancestor or lineal descendant of the disponer
All other cases
Any benefit received since 5 December 1991 within the same group threshold is aggregated for the purposes of determining whether any CAT is payable on the current benefit.
An exemption from CAT applies to gifts or inheritances received by a spouse or civil partner. Gifts of EUR3,000 or less are also exempt. Relief from CAT is available on gifts or inheritances of agricultural property and business property.
Ireland has entered into inheritance tax treaties with the United Kingdom and the United States.
Local Property Tax. Effective from 1 July 2013, an annual Local Property Tax (LPT) is charged on all residential properties in the Republic of Ireland. The LPT is due with respect to residential properties on a specific ownership date in any given year. For 2013, the ownership date was 1 May 2013. Residential property valuations for 2014 to 2020 remain similar to the valuations used for 2013 (even if improvements are made to the property). The
Payment. Tax on salaries and benefits normally is collected through the PAYE system.
Income tax self-assessment applies to self-employed individuals. These individuals include persons receiving rental income and investment income. Ninety percent of the tax due, including the USC (see Section B), for the year or an amount equal to 100% of the final liability of the preceding year must be paid by 31 October in the tax year to avoid an interest charge. Alternatively, income tax may be paid in 12 equal monthly installments throughout the tax year if agreement has been sought from the Irish tax authorities. The aggregate of these installments must equal 105% of the second preceding year’s liability, and must be paid by direct debit mandate (under this system, tax payments are deducted monthly from an individual’s bank account) if the individual had income tax liability in the second preceding year. Any balance of tax due must be paid by 31 October following the end of the tax year. A limited number of cases are selected for subsequent in-depth examination by the Revenue Commissioners.
Capital gains tax on gains arising on disposals during the period from 1 January to 30 November must be paid by 15 December in that tax year, and the tax on gains arising on disposals during the period from 1 December to 31 December must be paid by the following 31 January.
Tax administration dates. The following table presents important tax administration dates for the year ending 31 December 2024.
Pay balance of 2023 income tax liability
File 2023 income tax return
Pay 2024 preliminary tax equal to 90% of the actual income tax liability or 100% of the previous year’s final income tax liability
Capital gains tax due
Due date
31 October 2024
31 October 2024/ 15 November 2024*
31 October 2024
For period of 1 January 2024 through 30 November 2024 15 December 2024
For period of 1 December 2024 through 31 December 2024
File 2024 return
Balance of 2024 tax due
31 January 2025
31 October 2025
31 October 2025
* If a taxpayer files his is or her 2023 Irish tax return and pays any related tax liability online via the ROS, an extended deadline to 15 November 2024 is available.
E. Double tax relief and tax treaties
Ireland has entered into double tax treaties to avoid double taxation and to establish a right of taxation between Ireland and those countries. In general, the treaties provide for a credit for foreign taxes paid against the individual’s Irish income tax liabilities. Some treaties provide rules to determine the country where the individual is considered to be resident for tax purposes.
Ireland has entered into double tax treaties with the following jurisdictions.
only a single-entry visa. In May 2019, the Irish immigration authorities abolished the re-entry visa requirement that required visa-required nationals to obtain a re-entry visa after they registered their residency in Ireland (see Section H), to travel in and out of Ireland. Going forward after they arrive in Ireland, they must apply for a residence card, which allows them to travel in and out of Ireland while they remain resident without a separate re-entry visa. Non-EU nationals may be required to have employment permits if they intend to take up employment in Ireland. If an employment permit is required, non-EU nationals must have employment permits in their possession at the point of entry to Ireland.
In June 2014, the Irish and British governments issued a joint scheme, the British Irish Visa Scheme (BIVS), which allows visitors from China Mainland and India to travel freely within Ireland and the United Kingdom on either an Irish or UK visa. As a result, tourists and business visitors may visit both Ireland and the United Kingdom, including Northern Ireland, on a BIVS visa. This scheme applies only to individuals holding a short-stay visa (travel for up to 90 days).
G. Employment permits and self-employment
Employment permits. The Employment Permits Act 2024 legislates Irish employment permits. The following are the categories of employment permits:
• Critical Skills Employment Permit (CSEP)
• Intra-Company Transfer (ICT) Permit
• General Employment Permit (GEP)
• Contract for Services Employment Permit
• Dependent Employment Permit
• Internship Employment Permit
• Graduate Employment Permit
• Sports and Cultural Employment Permit
• Reactivation Employment Permit
• Seasonal Employment Permit
Each of the categories listed below has their own qualifying requirements and conditions. In general, EEA nationals, Swiss nationals and UK nationals (see Section H) do not require employment permits to live and work in Ireland. The Department of Enterprise, Trade and Employment (DETE) issues employment permits. Employers wishing to hire a non-EEA individual are required to apply for an employment permit on behalf of the applicant. An individual may also apply for an employment permit if he or she has received a job offer that is conditional on the holding of a valid employment permit. A signed copy of the individual’s employment contract is required for the application process. In addition to employment permits, depending on their country of origin, non-EU nationals may also need an entry visa (see Section F).
The Employment Permits Act 2024 allows the Minister for Enterprise, Trade and Employment to conduct regular reviews of the minimum remuneration levels for employment permits. A review is currently taking place (as of December 2024) and based on the outcome, the remuneration rates below may change.
The categories of the most commonly used permits in Ireland are summarized below.
Critical Skills Employment Permit. To obtain a Critical Skills Employment Permit, an individual must be employed under an Irish employment contract and paid directly from an Irish payroll. The minimum remuneration requirement is EUR64,000. Remuneration can be made up of Basic Annual Salary (equal to at least the Irish National Minimum Wage) and Health Insurance Payments. Individuals in all occupations except those that are contrary to public interest may qualify for a Critical Skills Employment Permit.
A non-EEA national who has been offered an Irish employment contract and will be paid directly from an Irish payroll may be eligible for a Critical Skills Employment Permit if the salary is between EUR38,000 and EUR63,999. The individual must hold a third-level qualification (at least a degree qualification) and the role must be included in the Critical Skills Occupations List.
A Critical Skills Employment Permit applies only if the offer of employment is for a period of at least two years. An initial permit is available for a two-year period (EUR1,000 fee). No more than 50% of employees of an Irish employer may be from non-EEA countries.
An individual who is granted an employment permit for the first time in Ireland is expected to stay with the initial employer for a period of nine months.
Extension of a Critical Skills Employment Permit. Critical Skills Employment permit holders who have completed 21 months of residence on Stamp 1 permission (based on Critical Skills Permit) in Ireland must apply to the Garda National Immigration Bureau (GNIB) or ISD Unit for a Stamp 4 Irish Residence Permit (IRP) card, formerly known as the GNIB card (see Section H) with appropriate documentation. If this condition is not met, an individual will need to seek a new employment permit to continue working in Ireland.
General Employment Permit. To obtain a General Employment Permit, an individual must be employed in an eligible occupation under an Irish employment contract and paid directly from an Irish payroll. The role must not be an excluded job category contained in the Ineligible Categories of Employment for Employment Permits.
The minimum remuneration requirement is EUR34,000. Remuneration can be made up of Basic Annual Salary (equal to at least the Irish National Minimum Wage) and Health Insurance Payments. The remuneration threshold is EUR30,000 with respect to employment permit applications under the General Employment Permit category for the following individuals:
• Non-EEA nationals in a health care assistant role if the individual has previously been in employment in Ireland on an employment permit as a health care assistant for two years or more and if he or she submits a copy of his or her relevant Level 5 Quality and Qualifications Ireland (QQI) qualification.
• Non-EEA nationals in the horticulture and meat processing sectors.
• A non-EEA national who has been granted international protection (refugee status or subsidiary protection)
• A non-EEA national who holds appropriate permission under the Immigrant Investor/Start-up Entrepreneur Programme
• A non-EEA national who is a registered student working less than 20 hours a week
• Swiss nationals
• UK nationals (see Section H)
Self-employment. Arising from an ongoing review of the business-, entrepreneur- and investor-related migration schemes, the Irish immigration authorities decided to suspend the Business Permission Scheme, effective from the close of business on 16 March 2016 until further notice. This does not affect applications received before 16 March 2016 or the status of persons already holding permission under the scheme.
Other immigration programs. The DJE has also introduced the programs described below.
Immigrant Investor Programme. This program has been closed for new applications since February 2023.
Start-up Entrepreneur Programme. Under the Start-up Entrepreneur Programme, non-EEA nationals with an innovative business idea for a High Potential Start-up and funding of EUR50,000 for the first founder (and EUR30,000 for any subsequent founders) can acquire residency in Ireland for the purposes of developing their business.
No initial job creation targets are set because it is recognized that such a business can take some time to get off the ground. The intention of the program is to support High Potential Start-ups, which are defined as enterprises that satisfy the following conditions:
• They introduce a new or innovative product or service to international markets.
• They are capable of creating 10 jobs in Ireland and realizing EUR1 million in sales within three to four years of starting up.
• They are led by an experienced management team.
• They are headquartered and controlled in Ireland.
• They are less than six years old.
This scheme is not intended for retail, personal services, catering or other similar businesses.
Successful applicants can expect to receive an initial permission of two years. Following a review at this point to ensure that the entrepreneur is continuing to progress with the business proposal, a further three years will be granted. After the initial five-year period, successful entrepreneurs will be free to apply for longterm residence in five-year periods.
Applications for this scheme are made to the DJE.
H. Residence permits and naturalization
Residence permits. EEA nationals, Swiss nationals and UK nationals are not required to apply for an Irish Residence Permit (IRP) card, formerly known as a GNIB card. Non-EEA and nonSwiss nationals who intend to remain longer than 90 days in