Ireland — Non-Domicile Status

|---| | Country | Ireland | | Non-dom benefit | Remittance basis on foreign income and gains | | Minimum tax | None (unlike Malta) | | Irish-source income | Taxed in full regardless of domicile | | Foreign income (not remitted) | Not taxed in Ireland | | Capital gains on Irish assets | 33% | | Capital gains on foreign assets (non-dom) | Remittance basis — taxed only if remitted | | Primary legislation | Taxes Consolidation Act 1997 (TCA), s.18-29 | | Tax authority | Revenue Commissioners (revenue.ie) | | Verified by | Pending — Irish tax adviser sign-off required |

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Section 2 — Who is Non-Dom in Ireland?

Domicile in Ireland follows general law (not tax law):

• Domicile of origin: derived from father's domicile at birth
• Domicile of choice: acquired by residing in a country with indefinite intent to remain

A foreign national living in Ireland who was born outside Ireland typically retains their foreign domicile of origin unless they form a definite intention to live in Ireland permanently and indefinitely.

Residency: Separate from domicile. An individual is ordinarily resident in Ireland after 3 consecutive years of Irish tax residence. "Ordinary residence" affects how long you remain taxable after departing Ireland.

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Section 3 — Remittance Basis: What Is Taxed

For an Irish resident who is non-domiciled:

Income/Gain type	Tax treatment
Income arising in Ireland	Taxed in full — Irish rates
Employment income from Irish employer	Taxed in full
Foreign income remitted to Ireland	Taxed at Irish rates
Foreign income NOT remitted to Ireland	Not taxed in Ireland
Capital gains on Irish assets	33% — taxed regardless
Capital gains on foreign assets, remitted	Taxed at 33%
Capital gains on foreign assets, NOT remitted	Not taxed

"Remittance": broadly interpreted — includes bringing money/assets to Ireland, using foreign income/gains to pay Irish debts, or acquiring property in Ireland with foreign funds.

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Section 4 — Clean Capital

Funds accumulated before becoming Irish tax resident are not remittances when brought to Ireland. These are "clean capital." Maintaining separate accounts for pre-Irish-residence capital vs post-residence income is strongly recommended.

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Section 5 — Ordinary Residence: The Trap

After 3 years of Irish tax residence, a person becomes ordinarily resident.

An ordinarily resident individual who leaves Ireland remains taxable on their worldwide income (not just Irish-source) for 3 years after departure — except:

• Foreign employment income (if duties performed wholly outside Ireland)
• Certain foreign-source income that is not remitted

Implication: Moving to Ireland and then leaving after a few years doesn't immediately terminate Irish tax obligations. This is similar to the UK's rule but differently structured.

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Section 6 — CGT: 33% on Irish Assets

Irish CGT rate: 33% on gains above the annual exemption.

Item	Rate/Amount
CGT rate	33%
Annual exemption (individual)	€1,270
Entrepreneur Relief	10% on qualifying business disposals (up to €1M lifetime)

Irish assets = Irish shares, Irish property, Irish business goodwill. A non-dom individual pays 33% CGT on gains from Irish assets regardless of domicile status.

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Section 7 — Comparison with UK Non-Dom

Feature	Ireland	UK (from April 2025)
Regime	Domicile-based remittance	4-year FIG for new residents (domicile rules transitioning out)
Duration	Indefinite while non-dom	4 years maximum FIG exemption
Minimum tax	None	None
Irish/UK source taxed in full	Yes	Yes
Annual exemption (CGT)	€1,270	£3,000

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Section 8 — Sources

• Taxes Consolidation Act 1997, Part 34 (residence, ordinary residence, domicile)
• Revenue: revenue.ie/en/life-events-and-personal-circumstances/moving-to-ireland/
• Revenue: IT4 — Residence, Ordinary Residence and Domicile

Working paper only. Irish domicile determination is fact-specific and can have significant estate tax implications in addition to income tax. Engage a qualified Irish tax adviser.