Ireland: cross-border tax for people and companies (2026)

This skill is the hub for what changes when a person or a company comes into or leaves Ireland. It summarises the rules and points to the detailed skills in this pack. The Irish tax year is the calendar year. The authority is the Revenue Commissioners. The law is the Taxes Consolidation Act 1997 (TCA 1997).

Detail lives elsewhere. Read ie-non-dom for domicile, ordinary residence and the remittance basis. Read ie-corporation-tax for the company side, ie-cgt for gains, ie-income-tax-form11 for the return, ie-payroll for PAYE, and ie-prsi-class-s for PRSI.

Who this applies to

Individuals: residence

An individual is resident in Ireland for a tax year if they are present here for:

• 183 days or more in the tax year, or
• 280 days or more across the tax year and the year before, taken together.

A person here for 30 days or less in a tax year is not resident for that year, and those days are ignored for the 280-day test. A day counts if the person is here for any part of it. (Revenue: resident for tax purposes; TDM Part 34-00-01)

Ireland has no "home" or "centre of interests" test in its domestic rules. Those ideas come in only through a tax treaty tie-breaker (see Cross-border points).

Election in the year of arrival. A person who is not resident on days can elect, in writing, to be resident for the year they arrive, if they satisfy Revenue that they are here with the intention, and in circumstances, that they will be resident the next year (section 819(3)). There is no way to withdraw the election (TDM Part 34-00-01).

Ordinary residence. After three consecutive tax years of residence, a person becomes ordinarily resident from the start of the fourth. After leaving, they stay ordinarily resident for three more tax years. (Revenue: ordinarily resident)

Domicile. Domicile is a general-law concept, not a days test. A resident who is not Irish domiciled can use the remittance basis on foreign income and on gains on foreign assets (section 71 and section 29(4) TCA 1997). The full rules, and what the remittance basis does not cover, are in ie-non-dom.

Split-year treatment (section 822 TCA 1997)

Split-year treatment applies to employment income only. It does not split the year for investment income or gains.

• Arrival: the person is resident in the year of arrival, was not resident the year before, and will be resident the year after. Employment income earned abroad before arrival is ignored. (Revenue: year of arrival)
• Departure: the person is resident in the year of departure and not resident the year after. Employment income earned abroad after departure is ignored. (Revenue: year of departure)

Finance Act 2024 changed how it is claimed. For arrivals and departures from 1 January 2025, the person can self-assess and claim it in the income tax return for that year. An in-year application is still needed where the benefit is wanted during the year, for example to get a PAYE Exclusion Order. (TDM Part 34-00-11, paragraph 5.1)

Companies: residence (section 23A TCA 1997)

• A company incorporated in Ireland is resident here, unless a tax treaty treats it as resident in the other country. This applies to companies incorporated on or after 1 January 2015, and to older Irish companies after the transition period ended on 31 December 2020.
• A company incorporated abroad is resident here if its central management and control is in Ireland.

(TDM Part 02-02-03; Revenue: company residency rules)

Rates, bands and thresholds

Item	Figure	Tax year	Source
Income tax, single person	20% on the first EUR 44,000, 40% on the balance	2026	Revenue: tax rates, bands and reliefs
Single person tax credit / Employee (PAYE) tax credit	EUR 2,000 each	2026	Revenue: tax rates, bands and reliefs
Non-resident tax credits	EU citizens: full credits if at least 75% of worldwide income is taxable in Ireland, otherwise a share by the ratio of Irish to total income. Citizens of a treaty country: full credits if their only income is Irish, otherwise a share. All others: none	2026	Revenue: non-residents
Ordinarily resident, not resident: other foreign income limit	EUR 3,810 (a cliff: above it, all of it is taxable)	2026	Revenue: ordinarily resident
SARP relief	30% of employment income between the lower threshold and EUR 1,000,000 is disregarded for income tax	Arrivals 2021 to 2030 (this skill does not cover earlier arrivals)	Finance Act 2025, section 23; TDM Part 34-00-10
SARP lower threshold ("B") and minimum annualised relevant income for each year of claim	EUR 125,000 for 2026 to 2030 arrivals; EUR 100,000 for 2023 to 2025 arrivals; EUR 75,000 for 2021 and 2022 arrivals. In the year of arrival or departure, B is reduced in proportion to the months employed	By year of arrival	Finance Act 2025, section 23; TDM Part 34-00-10, paragraphs 7 and 11
SARP minimum base salary in the year of arrival	Annualised EUR 125,000, excluding bonuses, commissions, benefits and share-based pay	Arrivals 2026 to 2030 only	Finance Act 2025, section 23 (new section 825C(2AB)(d))
SARP school fees paid tax-free	Up to EUR 5,000 per child per year	2026	TDM Part 34-00-10
CGT rate, most gains	33% for disposals to 6 October 2026; 31% for disposals from 7 October 2026 (development land stays at 33%)	2026	Revenue: how to calculate CGT
CGT annual personal exemption	EUR 1,270	2026	Revenue: how to calculate CGT
Company exit tax (section 627)	12.5%; the general CGT rate (see the row above) if the exit is part of a transaction to dispose of the asset and its purpose is to get the lower rate	Events from 10 October 2018	TDM Part 20-02-01; Revenue: exit tax
Temporary non-resident CGT (section 29A)	Shareholdings of 5% or more of a company's issued share capital, or worth more than EUR 500,000; non-residence of 5 years of assessment or less	2026	TDM Part 02-03-02
Dividend withholding tax (DWT)	25%	2026	Revenue: DWT
Yearly interest (section 246)	Standard rate of income tax (20% for 2026)	2026	TDM Part 08-03-06
Patent royalties (section 238)	Standard rate of income tax (20% for 2026)	2026	TDM Part 08-03-06
Rent paid to a non-resident landlord (section 1041)	20%	2026	TDM Part 45-01-04a

Ireland does not charge a separate rate on non-residents. A non-resident pays the normal 20% and 40% rates on income taxed here, usually without credits (see the credits row).

Ireland has no exit tax on individuals who leave. The only departure charge on individuals is the section 29A rule for temporary non-residents, which bites only if the person comes back within five years.

The taxable base

Resident and domiciled. Taxed on worldwide income and gains.

Resident, not domiciled. Irish income and Irish employment income in full. Foreign investment income and gains on foreign assets only when remitted to Ireland. Employment income for duties done in Ireland is never on the remittance basis. See ie-non-dom.

Not resident. What is taxed depends on ordinary residence and domicile (Revenue: non-residents):

• Ordinarily resident and domiciled: worldwide income, except income from a trade or employment carried on wholly abroad and other foreign income of EUR 3,810 or less.
• Not ordinarily resident and domiciled: Irish income, income from work done in Ireland, and Irish gains.
• Not ordinarily resident and not domiciled: Irish income, income from work done in Ireland, and gains on Irish specified assets only (land, buildings, minerals and assets of a trade carried on in Ireland).

SARP conditions (section 825C TCA 1997) (TDM Part 34-00-10; Revenue: conditions):

• Arrives in a tax year from 2012 to 2030, at the request of the employer, to work for it or an associated company in Ireland. 2030 is the last arrival year.
• Worked for that employer abroad for at least six months immediately before.
• Works in Ireland for at least 12 consecutive months from arrival.
• Not resident in Ireland in the five tax years before the year of arrival, and resident for each year the relief is claimed.
• For 2026 to 2030 arrivals, an annualised base salary of at least EUR 125,000 in the year of arrival. Bonuses, commissions, benefits and share-based pay do not count towards this floor, but they do count in the income the 30% applies to. Arrivals from 2023 to 2025 have no base-salary test; they need annualised relevant income of at least EUR 100,000 in each year of claim.
• In the year of arrival or departure, the lower threshold is reduced in proportion to the months employed in that year (TDM Part 34-00-10, paragraph 11).
• Relief runs for up to five consecutive years from the first year of entitlement.
• The relief is from income tax only. USC and PRSI are charged on the full salary, unless PRSI is relieved under an EU Regulation or a bilateral agreement.
• SARP cannot be combined with the remittance basis for that employment income, the Foreign Earnings Deduction or Transborder Workers' Relief.
• The employer may also pay one return trip a year for the family and school fees up to EUR 5,000 per child, free of tax, USC and PRSI.

Company exit tax (sections 627 to 629 TCA 1997). A deemed disposal at market value arises when a company moves assets from an Irish branch abroad, moves the branch's business abroad, or an Irish-resident company moves its residence abroad. Assets on which Ireland keeps the taxing right (for example Irish land, and unquoted shares deriving their value from it, still used by an Irish branch) are excluded. (TDM Part 20-02-01)

Temporary non-residents (section 29A TCA 1997). An Irish-domiciled individual who leaves, is not taxable in Ireland for five years of assessment or less, and disposes of a qualifying shareholding while away, is treated as having disposed of it on the last day of the last year of residence. Since Finance Act 2014, the market value used is the value on the day of the actual disposal. (TDM Part 02-03-02)

Deadlines and filing

• Income tax return (Form 11): 31 October after the tax year. For the 2025 return, the date is extended to 18 November 2026 where the person both pays and files through ROS. (Revenue: pay and file)
• SARP: the employer certifies the employee on Form SARP 1A within 90 days of arrival. For arrivals from 1 January 2026, a late certification within 180 days is accepted, but then the first year is lost and relief runs for the next four years. A SARP claimant is a chargeable person and must file an annual return. (TDM Part 34-00-10)
• Split-year treatment: claimed in the income tax return for the year of arrival or departure, or by writing to Revenue through MyEnquiries where the benefit is wanted during the year.
• Election to be resident in the year of arrival: in writing to Revenue.
• PAYE Exclusion Order (section 984 TCA 1997): the employer applies through the online portal on ROS or myAccount. (TDM Part 42-04-01)
• Company exit tax: due with corporation tax, by day 23 of the month in which the nine months after the exit event end. A company can elect in its return to pay in equal instalments over five years where the assets go to an EU or qualifying EEA state; it then files an annual statement within 21 days after the end of each of the five calendar years. (TDM Part 20-02-01)
• DWT: return and payment by day 14 of the month after the month the dividend is paid. (Revenue: DWT payment and filing)
• Non-resident landlord withholding: the tenant or collection agent files a Rental Notification and pays over 20% of gross rent. The landlord still files their own Form 11 or CT1. (TDM Part 45-01-04a)

Penalties and interest

• Late income tax return: a surcharge of 5% of the tax due, up to EUR 12,695, if filed within two months of the deadline; 10%, up to EUR 63,485, after that. (Revenue: pay and file)
• Late income tax, corporation tax and CGT: interest at 0.0219% a day (section 1080 TCA 1997), for each day or part of a day the tax is unpaid. (Revenue: guidelines for charging interest on late payment, paragraph 4.2; Revenue: CT payment and filing)
• Deferred exit tax: simple interest on tax outstanding, payable at the same time as the tax. The rest of the tax and interest falls due at once if the assets are sold, the assets or the company move to a country outside the EU and qualifying EEA states, the company becomes insolvent or goes into liquidation, or an instalment is missed and not paid within 12 months. (TDM Part 20-02-01)
• SARP: an employer who misses the 90-day certification deadline costs the employee the relief (arrivals to 2025). For arrivals from 2026, certification between 90 and 180 days costs the first year; after 180 days the relief is lost.

Cross-border points

Treaty tie-breaker. Where a person is resident in Ireland and in a treaty country, the treaty decides. The usual order is permanent home, then centre of vital interests, then habitual abode, then nationality. For companies, section 23A follows the treaty: a company the treaty puts in the other country is not Irish resident.

Double tax relief. Ireland generally gives a credit for foreign tax against Irish tax on the same income. Under SARP, employment income that gets a foreign tax credit is taken out of the income the 30% applies to (TDM Part 34-00-10, paragraph 8).

Non-resident employees and the PAYE Exclusion Order. An Irish employer must operate PAYE unless Revenue issues an Exclusion Order. One can issue where the employee is not resident for the year and works wholly outside Ireland. Duties here on fewer than 30 days in a tax year count as incidental and are ignored. In a departure year, the order can run from the departure date with split-year treatment. The order relieves income tax and USC only. PRSI may still be due. Directors of Irish companies are treated differently. (TDM Part 42-04-01)

Dividends paid abroad. DWT at 25% does not apply to a non-resident who files a declaration: individuals resident in an EU or EEA state or a treaty country (Form V2A, certified by their tax authority), companies resident there and not controlled from Ireland (Form V2B), and some 75% subsidiaries of listed companies. The exemption runs to 31 December of the fifth year after it is issued. (Revenue: DWT exemptions for non-residents)

Interest and royalties paid abroad. Section 246(3) has a long list of exemptions for interest, applied without Revenue approval. Royalties paid by a company in the course of its trade to a company in a treaty country are exempt under section 242A, and payments to an associated EU company under the Interest and Royalties Directive. A treaty can cap the rate. Since Finance (No. 2) Act 2023, these exemptions are switched off for payments to associated entities in zero-tax or no-tax territories or on the EU list of non-cooperative jurisdictions. (TDM Part 08-03-06)

EU social security. Under Regulations (EU) 883/2004 and 987/2009, a worker is insured in one country at a time, normally where they work. A worker posted from Ireland to another EU or EEA state (or Switzerland or the UK) for up to 24 months stays in Irish PRSI with a Portable Document A1, applied for on form EUW1. Someone working in two or more states is insured where they live if they do a substantial part (25% is the indicator) of their work there. Ireland's bilateral agreements cover postings to Australia (4 years), Canada (2), Japan (5), New Zealand (2), Korea (5), Quebec (2), the UK (3) and the USA (5). (DSP operational guidelines, updated 7 January 2026) Class S PRSI for the self-employed is in ie-prsi-class-s.

Other skills. The company side of migration, Pillar Two and the participation exemption are in ie-corporation-tax. CGT on Irish assets of non-residents is in ie-cgt. Gifts and inheritances with a foreign element are in ie-cat.

Worked examples

Example 1: an assignee moves to Dublin in 2026 under SARP

Anna has worked for a US group for three years. It sends her to its Irish subsidiary on 1 February 2026 for three years. She has never been resident in Ireland. Her annual base salary is EUR 240,000, so she earns EUR 220,000 from the Irish employment in the 11 months from February to December 2026, with no bonus or pension contribution. She is single. The employer certifies Form SARP 1A within 90 days.

• She is resident for 2026 (more than 183 days) and meets the SARP conditions. Her annual base salary is above EUR 125,000.
• She is employed for 11 months of 2026, so the lower threshold is reduced: 125,000 times 11/12 = EUR 114,583.33 (TDM Part 34-00-10, paragraph 11).
• Specified amount: (220,000 minus 114,583.33) times 30% = EUR 31,625. This is disregarded for income tax.
• Taxable for income tax: 220,000 minus 31,625 = EUR 188,375.
• Tax: 20% of 44,000 = 8,800. 40% of 144,375 = 57,750. Total 66,550.
• Less the single person and employee credits of EUR 2,000 each: income tax EUR 62,550.
• Without SARP the income tax would be EUR 75,200, so SARP saves EUR 12,650 (40% of the 31,625).
• USC and PRSI are on the full EUR 220,000 (see ie-usc and ie-payroll); they are not computed here.
• Her January salary, earned abroad before arrival, is outside Irish tax under split-year treatment, which she claims in her 2026 return.

name: SARP 2026 arrival on 1 February, annual salary EUR 240,000, single
inputs:
  irish_income: 220000
  lower_threshold: 125000
  months: 11
  upper_threshold: 1000000
  band: 44000
  credits: 4000
steps:
  - threshold_apportioned: lower_threshold * months / 12
  - specified_amount: (min(irish_income, upper_threshold) - threshold_apportioned) * 0.30
  - taxable: irish_income - specified_amount
  - tax_with_sarp: band * 0.20 + (taxable - band) * 0.40 - credits
  - tax_without_sarp: band * 0.20 + (irish_income - band) * 0.40 - credits
  - saving: tax_without_sarp - tax_with_sarp
expected:
  threshold_apportioned: 114583.33
  specified_amount: 31625.00
  taxable: 188375.00
  tax_with_sarp: 62550.00
  tax_without_sarp: 75200.00
  saving: 12650.00

Example 2: an Irish company moves its residence to the Netherlands

An Irish-resident trading company moves its central management to the Netherlands and becomes Dutch resident under the treaty. On the day before it ceases to be resident it holds software and a brand. The deemed disposal at market value gives a gain of EUR 1,900,000 on one asset and a loss of EUR 400,000 on another, a net gain of EUR 1,500,000 (figures adapted from Example 1 in TDM Part 20-02-01, where the same net gain arises on a branch transfer). No anti-avoidance purpose applies, so the rate is 12.5%.

• Exit tax: 1,500,000 times 12.5% = EUR 187,500.
• The assets go to an EU state, so the company can elect in its return to pay in five equal instalments: EUR 37,500 a year, the first due with the corporation tax for the period (day 23 of the ninth month after the exit), plus simple interest on the deferred tax.
• It files an annual statement within 21 days of the end of each of the next five calendar years. If it sells the assets, moves them or itself outside the EU and qualifying EEA states, becomes insolvent, or misses an instalment for more than 12 months, the rest falls due at once.

name: Company migration, net gain EUR 1,500,000, 12.5% exit tax over five instalments
inputs:
  gain_software: 1900000
  loss_brand: 400000
  rate: 0.125
  instalments: 5
steps:
  - net_gain: gain_software - loss_brand
  - exit_tax: net_gain * rate
  - instalment: exit_tax / instalments
expected:
  net_gain: 1500000.00
  exit_tax: 187500.00
  instalment: 37500.00

Ask the client first

1. Dates in and out of Ireland in this tax year and the last one, counting any part of a day.
2. Domicile of origin, citizenship, and whether they have ever been resident or ordinarily resident in Ireland (the last five years matter for SARP; the last three for ordinary residence).
3. For an employee: who employs them, how long they worked for that group abroad, the base salary, and whether the employer will certify SARP within 90 days of arrival.
4. Where the duties are done, and how many days are worked in Ireland after leaving (fewer than 30 counts as incidental).
5. For a company: where it is incorporated, where the board meets and decides, and whether it plans to move assets, a branch or its residence abroad.
6. For someone leaving: whether they hold 5% or more of a company, or shares worth more than EUR 500,000, and whether they may come back within five years.

Sources

Read on 2026-10-22:

• Taxes Consolidation Act 1997 (sections 23A, 29, 29A, 71, 238, 242A, 246, 627 to 629, 819, 820, 822, 825C, 984, 1041): https://www.irishstatutebook.ie/eli/1997/act/39/enacted/en/html
• Revenue, resident for tax purposes: https://www.revenue.ie/en/jobs-and-pensions/tax-residence/resident-for-tax-purposes.aspx
• Revenue, ordinarily resident: https://www.revenue.ie/en/jobs-and-pensions/tax-residence/ordinarily-resident-tax-purposes.aspx
• Revenue, non-residents and tax credits: https://www.revenue.ie/en/jobs-and-pensions/tax-residence/non-residents.aspx
• Revenue, split-year treatment, arrival: https://www.revenue.ie/en/life-events-and-personal-circumstances/moving-to-or-from-ireland/moving-or-returning-to-ireland/split-year-treatment-in-your-year-of-arrival.aspx
• Revenue, split-year treatment, departure: https://www.revenue.ie/en/life-events-and-personal-circumstances/moving-to-or-from-ireland/leaving-ireland/split-year-treatment-in-your-year-of-departure.aspx
• TDM Part 34-00-01, residence (last updated February 2025): https://www.revenue.ie/en/tax-professionals/tdm/income-tax-capital-gains-tax-corporation-tax/part-34/34-00-01.pdf
• TDM Part 34-00-11, split year residence (reviewed September 2025): https://www.revenue.ie/en/tax-professionals/tdm/income-tax-capital-gains-tax-corporation-tax/part-34/34-00-11.pdf
• Finance Act 2025, section 23 (amends section 825C for 2026 to 2030 arrivals): https://www.irishstatutebook.ie/2025/en/act/pub/0018/sec0023.html
• TDM Part 34-00-10, SARP (last updated March 2026): https://www.revenue.ie/en/tax-professionals/tdm/income-tax-capital-gains-tax-corporation-tax/part-34/34-00-10.pdf
• Revenue, SARP conditions: https://www.revenue.ie/en/personal-tax-credits-reliefs-and-exemptions/income-and-employment/special-assignee-relief-programme/what-are-the-conditions-to-qualify.aspx
• Revenue, tax rates, bands and reliefs: https://www.revenue.ie/en/personal-tax-credits-reliefs-and-exemptions/tax-relief-charts/index.aspx
• Revenue, how to calculate CGT: https://www.revenue.ie/en/gains-gifts-and-inheritance/transfering-an-asset/how-to-calculate-cgt.aspx
• TDM Part 02-02-03, company residence (last reviewed May 2026): https://www.revenue.ie/en/tax-professionals/tdm/income-tax-capital-gains-tax-corporation-tax/part-02/02-02-03.pdf
• Revenue, company residency rules: https://www.revenue.ie/en/companies-and-charities/corporation-tax-for-companies/corporation-tax/company-residency-rules.aspx
• TDM Part 02-03-02, temporary non-residents (last reviewed December 2024): https://www.revenue.ie/en/tax-professionals/tdm/income-tax-capital-gains-tax-corporation-tax/part-02/02-03-02.pdf
• TDM Part 20-02-01, exit tax (last reviewed October 2025): https://www.revenue.ie/en/tax-professionals/tdm/income-tax-capital-gains-tax-corporation-tax/part-20/20-02-01.pdf
• Revenue, exit tax provisions: https://www.revenue.ie/en/companies-and-charities/anti-beps-measures/exit-tax-provisions.aspx
• Revenue, DWT: https://www.revenue.ie/en/companies-and-charities/dividend-withholding-tax/index.aspx
• Revenue, DWT exemptions for non-residents: https://www.revenue.ie/en/companies-and-charities/dividend-withholding-tax/exemptions-for-non-residents.aspx
• Revenue, DWT payment and filing: https://www.revenue.ie/en/companies-and-charities/dividend-withholding-tax/payment-and-filing-a-return.aspx
• TDM Part 08-03-06, interest and royalties withholding (last reviewed May 2026): https://www.revenue.ie/en/tax-professionals/tdm/income-tax-capital-gains-tax-corporation-tax/part-08/08-03-06.pdf
• TDM Part 45-01-04a, non-resident landlord withholding tax (updated October 2025): https://www.revenue.ie/en/tax-professionals/tdm/income-tax-capital-gains-tax-corporation-tax/part-45/45-01-04a.pdf
• TDM Part 42-04-01, PAYE Exclusion Order (last updated July 2026): https://www.revenue.ie/en/tax-professionals/tdm/income-tax-capital-gains-tax-corporation-tax/part-42/42-04-01.pdf
• Revenue, pay and file: https://www.revenue.ie/en/self-assessment-and-self-employment/guide-to-self-assessment/pay-file-system.aspx
• Revenue, guidelines for charging interest on late payment (updated July 2024): https://www.revenue.ie/en/tax-professionals/tdm/collection/debt-management/Guidelines-for-charging-interest-on-late-payment-20240715074235.pdf
• Revenue, CT payment and filing: https://www.revenue.ie/en/companies-and-charities/corporation-tax-for-companies/corporation-tax-payment-and-filing/payment-and-filing.aspx
• Department of Social Protection, PRSI for those working abroad (updated 7 January 2026): https://www.gov.ie/en/department-of-social-protection/publications/operational-guidelines-prsi-for-those-working-abroad-and-the-special-prsi-collection-system/

Not yet confirmed: the interest rate on deferred exit tax (TDM Part 20-02-01 says only that simple interest is charged); the 31% CGT rate from 7 October 2026 is stated by Revenue but comes from Budget 2027 and the Finance Bill 2026 was not yet enacted when read, so the exit tax anti-avoidance rate for events from that date follows whatever is enacted; the treaty tie-breaker order, which is the OECD model wording and must be read in the specific treaty; Revenue's tax rates page notes Budget 2027 changes announced on 6 October 2026, which do not affect 2026 bands and credits.

Contributed by Ryan Duguid.