Date de publication : 06-10-1907
The following information are for the sole purpose of providing a general overview of the local taxation of the Corporate tax aspects of the country. In any case, it can not replace a tax advice, or be considered as an official information.
Yes we tax in Ireland
New tax reform: No specific information
New tax treaties:
- Negotiations related to the tax treaty between Ireland and Uruguay are now concluded.
- Negotiations related to the tax treaty between Ireland and Oman are now concluded.
- Tax treaty between Ireland and Kosovo is under negotiation.
- Tax treaty between Ireland and Kazakhstan is signed.
Local tax advisors
No specific information on the local tax advisors.
Resident companies are taxed on their worldwide income.
The definition of resident company for tax purposes, corresponds to the definition of the OECD Model Convention. As per article 4 of the OECD Model Tax Convention, a person is treated as resident of a contracting state if he is liable to tax in such a country by virtue of his domicile, residence or place of management or any other similar criterion.
Entities are considered to be resident for tax purposes in Ireland if their place of management & control is in Ireland. Furthermore a company incorporated in Ireland is considered resident for tax purpose (even if its management and control is abroad).
However, the place of residence is subject to the relevant provisions of any applicable double tax treaty, if any.
Corporate Income Tax
The general CIT tax rate is 12.5%.
Non-taxable income includes the following:
- Dividends (participation exemption)
- Interest on overpaid taxes
Non-deductible expenses includes the following:
- Dividends benefiting from the participation exemption
Carry forward: Yes indefinitely, but some restrictions may apply
Carry back: Yes, but some restrictions may apply
Companies should submit an annual tax return.
Annual tax returns are established by the company on a self-assessment system.
Companies shall pay 2 advance payments.
Whithholding Taxes (payment to foreign companies)
The local tax rates in Ireland are the following, subject to the provisions of an applicable double tax treaty, if any.
There is no WHT on the profits paid from a branch to its foreign head office
The general rate of WHT on dividends is 20%.
The general rate of WHT on interest is 20%.
The general rate of WHT on Royalties is 20%.
The general rate of WHT on management fees is 0%.
The general rate of WHT on technical services is 0%.
Capital gains are taxed under a separate tax rate of 33% until 1mEUR and 20% for the portion of the capital gain up to 1mEUR.
There is a participation exemption for the minimum 5% subsidiaries held for a continuous period of at least 12 months.
Standard VAT tax rate is 23%
Reduced tax rates are:
- 5% (among others, immovable property, fuel, electricity, care of the human);
- 9% (among others, hotel, restaurant, theatres, museums, magazines and newspapers)
- 2% (among others, livestock, agricultural services)
Zero-rated supplies include, subject to certain conditions:
- exports of goods;
- intra-Community supplies of goods;
- food and drink used for human consumption,
Exempt supplies include, subject to certain conditions:
- Financial services ;
- Insurance services ;
- Training and education ;
- Transport of passengers;
EU taxable companies may claim a VAT refund to their own tax authorities through on the basis of the 13th EU Directive.
Certain non-resident companies (which are not required to register and incur Ireland VAT in the course of their business activities in Ireland) may apply for a refund.
No other specific information of VAT in Ireland.
The general statute of limitation is 4 years starting at the end of the year in which the tax return had to be filed.
There is no foreign exchange control in Ireland. Income and capital can be freely repatriated.
There are no thin capitalization rules in Ireland.
Do not hesitate to share your experience in Ireland with us in the comments below. Any comments are welcome !