Ireland's Non-Dom Remittance Basis: A Practical Guide

Ireland's Non-Dom Regime: Overview

Ireland operates a remittance basis of taxation for individuals who are:

• Irish tax-resident (present in Ireland for 183+ days in a tax year, or 280+ days across two consecutive years), and
• Not Irish-domiciled (their permanent home, as a matter of general law, is outside Ireland)

Under the remittance basis, a non-domiciled Irish tax-resident individual is subject to Irish income tax on:

• Irish-source income — taxed in full, regardless of whether it is remitted
• Employment income for duties performed in Ireland — taxed in full
• Foreign income and gains that are remitted to Ireland — taxed only to the extent the income or gains are brought into or enjoyed in Ireland

Foreign income and gains that are not remitted to Ireland are not subject to Irish tax.

This regime is codified in Section 71 of the Taxes Consolidation Act 1997 (for income) and Section 29(3) of the Capital Gains Tax Act (now consolidated into the TCA 1997) for capital gains.

Ireland vs UK: Why Ireland's Regime Is Now Superior

The United Kingdom abolished its non-dom remittance basis regime effective 6 April 2025, replacing it with a 4-year Foreign Income and Gains (FIG) exemption for new arrivals, after which all worldwide income and gains become fully taxable.

Ireland's regime, by contrast:

• Has no time limit — a non-dom can remain on the remittance basis indefinitely, provided they remain non-Irish-domiciled
• Has no annual charge — unlike the UK regime (which charged £30,000-£60,000 per year for long-term non-doms), Ireland imposes no fee for using the remittance basis
• Applies to both income and capital gains
• Has no deemed domicile rule — there is no provision under Irish law that deems an individual to become Irish-domiciled after a specified number of years of residence (unlike the UK's former 15-year deemed domicile rule for IHT purposes)

This makes Ireland one of the most generous non-dom regimes remaining in any major developed economy.

What Is Domicile?

Domicile of Origin

Every individual acquires a domicile of origin at birth — typically the domicile of their father (or mother, if born outside marriage). The domicile of origin is a matter of general law, not tax law, and is determined by the individual's permanent home at the time of birth.

Domicile of Choice

An individual can acquire a domicile of choice in Ireland by:

1. Taking up residence in Ireland, and
2. Forming the intention to remain in Ireland permanently or indefinitely

Both elements must be present. Mere residence — even long-term residence — is not sufficient without the intention to make Ireland a permanent home. Evidence of intention includes:

• Purchasing a permanent home in Ireland (as opposed to renting)
• Making an Irish will
• Joining Irish social and community organisations
• Disposing of property and connections in the country of origin
• Public statements of intention to remain in Ireland

Retaining Non-Dom Status

To maintain non-Irish-domicile status, an individual should:

• Retain connections to their country of domicile of origin — maintaining a home, bank accounts, social ties, and legal documents (will, etc.) in the country of origin
• Avoid acquiring an Irish domicile of choice — not expressing (publicly or in legal documents) an intention to remain in Ireland permanently
• Not dispose of all connections to the country of origin — maintaining the ability and intention to return
• Obtain formal advice — domicile is a complex area of law, and formal legal advice should be obtained at the outset of Irish residence

The Remittance Basis in Practice

What Is a "Remittance"?

A remittance occurs when foreign income or gains are brought into, received in, or used in Ireland. This includes:

• Direct transfers of money from an overseas account to an Irish account
• Use of a foreign credit card or debit card in Ireland (to the extent the payment source is foreign income)
• Importation of assets purchased with foreign income (e.g., importing a car, artwork, or jewellery purchased abroad)
• Constructive remittances — where foreign income is used to service an Irish debt, or where a third party brings foreign income into Ireland on the individual's behalf

What Is Not a Remittance?

• Capital — the remittance basis applies to income and gains, not to capital. Foreign capital (e.g., the original investment amount, or assets acquired before becoming Irish-resident) can be brought into Ireland without triggering a tax charge. The challenge is tracing — the individual must be able to demonstrate that remitted funds represent capital, not income or gains.
• Income earned before becoming Irish-resident — pre-arrival income is capital for remittance purposes
• Exempt income — income that is exempt from Irish tax (e.g., certain government pensions, exempt foreign employment income) is not taxable even if remitted

Segregation of Accounts

The most important practical step for a non-dom on the remittance basis is the segregation of overseas accounts:

• Capital account: Holds pre-arrival capital and subsequent capital contributions — funds from this account can be remitted to Ireland without tax
• Income account: Receives all post-arrival foreign income (dividends, interest, rental income, employment income from overseas duties)
• Gains account: Receives all post-arrival capital gains from disposal of foreign assets

By maintaining strict segregation, the individual can remit capital freely while keeping foreign income and gains offshore. Mixing capital and income in a single account creates a tracing problem — Irish Revenue applies a "first in, first out" (FIFO) basis, treating remittances as being made from the earliest deposits, which may include income.

Irish-Source Income: No Remittance Benefit

The remittance basis provides no benefit for Irish-source income. All income arising in Ireland is fully taxable regardless of domicile status:

• Irish employment income — salary, bonuses, benefits in kind for duties performed in Ireland
• Irish property income — rental income from Irish real estate
• Irish business income — profits from a trade carried on in Ireland
• Irish investment income — dividends from Irish companies, interest from Irish banks

Split-Year Treatment

For employment income, the remittance basis applies to duties performed outside Ireland. An individual who splits their working time between Ireland and overseas can apportion their employment income:

• Irish duties income: Fully taxable in Ireland
• Foreign duties income: Taxable only if remitted to Ireland (for non-doms on the remittance basis)

This split is based on actual working days, and detailed records (diaries, travel records, employer certifications) should be maintained.

Capital Gains Tax

Non-domiciled Irish residents are subject to Irish CGT at 33% on:

• Gains from the disposal of Irish assets (regardless of remittance)
• Gains from the disposal of foreign assets — only to the extent the gains are remitted to Ireland

Foreign capital gains that are not remitted are not subject to Irish CGT.

Capital Acquisitions Tax (CAT) — Inheritance and Gift Tax

Ireland levies Capital Acquisitions Tax at 33% on gifts and inheritances. For non-domiciled individuals:

• Irish-situs assets (Irish property, Irish company shares, Irish bank deposits) are subject to CAT regardless of the domicile of the donor/beneficiary
• Foreign-situs assets are subject to CAT only if either the donor or the beneficiary is Irish-resident or Irish-domiciled at the date of the gift/inheritance

A non-domiciled individual who receives a gift or inheritance of foreign assets from a non-Irish-resident, non-Irish-domiciled donor is not subject to Irish CAT — even if the beneficiary is Irish-resident.

Practical Structuring

Offshore Investment Structures

Non-doms commonly use:

• Overseas investment companies — a company incorporated outside Ireland (e.g., BVI, Cayman, IOM) that holds an investment portfolio. Dividends are not remitted if retained in the company; capital gains on disposal of the company's shares are not taxable if the shares are foreign assets and the gain is not remitted
• Overseas trusts — a trust established outside Ireland by a non-Irish-domiciled settlor, holding foreign assets. Trust distributions are taxable only if remitted
• Foreign pension arrangements — certain overseas pension plans are not subject to Irish tax until benefits are drawn and remitted

Clean Capital Planning

Before becoming Irish-resident, individuals should:

1. Crystallise all gains — dispose of and reacquire investment assets to establish a high base cost, so that future gains are minimised
2. Segregate accounts — separate capital from income into distinct bank accounts with clear paper trails
3. Document pre-arrival wealth — obtain bank statements, portfolio valuations, and property appraisals as of the date of arrival in Ireland
4. Take formal advice on domicile status, account segregation, and the interaction with their country of origin's tax laws

Key Takeaways

• Ireland's non-dom remittance basis has no time limit, no annual charge, and no deemed domicile rule — making it one of the most generous regimes in the developed world
• Foreign income and gains are taxable only when remitted to Ireland; foreign capital can be remitted freely
• Account segregation is essential — mixing capital and income creates tracing problems under Revenue's FIFO approach
• The remittance basis provides no benefit for Irish-source income, which is fully taxable regardless of domicile
• Pre-arrival planning (gain crystallisation, account segregation, wealth documentation) is critical to maximising the benefit
• Following the UK's abolition of its non-dom regime in April 2025, Ireland has become the leading English-speaking destination for non-domiciled individuals seeking a favourable personal tax environment