Ireland: sourced answers

75 (78 signed)

Treaties in force

«78 countries; 75 are in effect. The agreements cover direct taxes, which in the case of Ireland are: Income Tax Universal Social Charge Corporation Tax Capital Gains Tax. The following is a summary of the work underway to expand and enhance Ireland’s DTA network: Ireland and Oman signed a DTA on 30 May 2024. The DTA came into force on 18 December 2024. Its provisions began to take effect on 1 January 2025. Ireland and Liechtenstein signed a DTA on 30 October 2024. The Protocol to the existing DTA between Ireland and Jersey entered into force on 16 May 2025. Its provisions began to take effect on 1 January 2026. Ireland and Kosovo signed a DTA on 25 June 2021. The DTA came into force on 24 February 2022. Its provisions be»

Source: revenue.ie · source copy as of 2026-10-03

75 tax treaties in force

«78 countries; 75 are in effect. The agreements cover direct taxes, which in the case of Ireland are: Income Tax Universal Social Charge Corporation Tax Capital Gains Tax. The following is a summary of the work underway to expand and enhance Ireland’s DTA network: Ireland and Oman signed a DTA on 30 May 2024. The DTA came into force on 18 December 2024. Its provisions began to take effect on 1 January 2025. Ireland and Liechtenstein signed a DTA on 30 October 2024. The Protocol to the existing DTA between Ireland and Jersey entered into force on 16 May 2025. Its provisions began to take effect on 1 January 2026. Ireland and Kosovo signed a DTA on 25 June 2021. The DTA came into force on 24 February 2022. Its provisions be»

Source: revenue.ie · source copy as of 2026-10-03

Applies when: capital gains; company (legal entity)

Exempt: 5% held 12 months in prior two years, trading test (s. 626B)

Gain on selling the subsidiary

«trading requirement. Shareholding Requirement The investor company must be, or have been, a parent (as defined in section 626B (1)(b)(i)) of the investee company. To qualify for exemption the disposal must either:  have taken place when the investor company was a parent of the investee company. (An investor company is regarded as a parent company of an investee company at any time if that time is within a continuous period of 12 months throughout which the investor has a “real” holding of at least 5 per cent of the investee company), or  have taken place within 2 years of the most recent time that the investor»

Source: revenue.ie · source copy as of 2026-10-03

«at least 5 per cent of the investee company), or  have taken place within 2 years of the most recent time that the investor company was a parent of the investee company. Residence Requirement The investee company must be resident in a relevant territory, i.e. an EU Member State, a territory with which Ireland has a double tax treaty in force or a territory with which Ireland has signed a double tax treaty which has yet to come into force. Trading Requirement At the time of the disposal of shares a trading condition must be met. This trading requirement can be satisfied by either the investee company or the gr»

Source: revenue.ie · source copy as of 2026-10-03

«12 months throughout which the investor has a “real” holding of at least 5 per cent of the investee company), or  have taken place within 2 years of the most recent time that the investor company was a parent of the investee company. Residence Requirement The investee company must be resident in a relevant territory, i.e. an EU Member State, a territory with which Ireland has a double tax treaty in force or a territory with which Ireland has signed a double tax treaty which has yet to come into force. Trading Requirement At the time of the disposal of shares a trading condition must be met. This trading requirement can be satisfied»

Source: revenue.ie · source copy as of 2026-10-03

foreign-dividend participation exemption from 1 Jan 2025 for a 5% holding held 12 months in a subsidiary resident in an EU/EEA or treaty state

«at least five per cent of the ordinary share capital of the relevant subsidiary. This is referred to as a qualifying participation. This must be held for a continuous period of at least 12 months. This period must include the date the relevant distribution is made. What is a relevant subsidiary? On the date a company makes a relevant distribution, that company must be: resident for foreign tax purposes in a relevant territory, and not generally exempt from foreign tax. The company must also have met the above conditions throughout the preceding five years, for relevant distributions made during 2025. For relevant distributions made from 1 January 2026, the company must have been, throughout the preceding three ye»

Source: revenue.ie · source copy as of 2026-10-03

«From 2026, a "relevant territory" includes a non-treaty country that generally applies a withholding tax on cross-border distributions. This withholding tax must be imposed at a nominal rate greater than zero per cent. The exemption only applies to a distribution from a non-treaty country where withholding tax is: paid on the full amount of the distribution and not refunded. What distributions qualify for exemption? A relevant distribution is a distribution made in respect of a relevant subsidiary's share capital. The distribution can be made out of the profits of the relevant subsidiary. Alternatively, the distribution can be made out of other assets of the relevant subsidiary. This is provided that»

Source: revenue.ie · source copy as of 2026-10-03

«at least 12 months. This period must include the date the relevant distribution is made. What is a relevant subsidiary? On the date a company makes a relevant distribution, that company must be: resident for foreign tax purposes in a relevant territory, and not generally exempt from foreign tax. The company must also have met the above conditions throughout the preceding five years, for relevant distributions made during 2025. For relevant distributions made from 1 January 2026, the company must have been, throughout the preceding three years: Irish tax resident or resident for foreign tax purposes in a relevant territory and not generally exempt from foreign tax. A relevant territory is an EU or EEA country»

Source: revenue.ie · source copy as of 2026-10-03

Applies when: dividends and profit distributions; company (legal entity)

5% for 12 months; payer in EU/EEA/treaty state (s. 831B, from 2025; widened from 2026)

Dividend exemption: threshold / holding

«at least five per cent of the ordinary share capital of the relevant subsidiary. This is referred to as a qualifying participation. This must be held for a continuous period of at least 12 months. This period must include the date the relevant distribution is made. What is a relevant subsidiary? On the date a company makes a relevant distribution, that company must be: resident for foreign tax purposes in a relevant territory, and not generally exempt from foreign tax. The company must also have met the above conditions throughout the preceding five years, for relevant distributions made during 2025. For relevant distributions made from 1 January 2026, the company must have been, throughout the preceding three ye»

Source: revenue.ie · source copy as of 2026-10-03

«From 2026, a "relevant territory" includes a non-treaty country that generally applies a withholding tax on cross-border distributions. This withholding tax must be imposed at a nominal rate greater than zero per cent. The exemption only applies to a distribution from a non-treaty country where withholding tax is: paid on the full amount of the distribution and not refunded. What distributions qualify for exemption? A relevant distribution is a distribution made in respect of a relevant subsidiary's share capital. The distribution can be made out of the profits of the relevant subsidiary. Alternatively, the distribution can be made out of other assets of the relevant subsidiary. This is provided that»

Source: revenue.ie · source copy as of 2026-10-03

«at least 12 months. This period must include the date the relevant distribution is made. What is a relevant subsidiary? On the date a company makes a relevant distribution, that company must be: resident for foreign tax purposes in a relevant territory, and not generally exempt from foreign tax. The company must also have met the above conditions throughout the preceding five years, for relevant distributions made during 2025. For relevant distributions made from 1 January 2026, the company must have been, throughout the preceding three years: Irish tax resident or resident for foreign tax purposes in a relevant territory and not generally exempt from foreign tax. A relevant territory is an EU or EEA country»

Source: revenue.ie · source copy as of 2026-10-03

foreign-dividend participation exemption from 1 Jan 2025 for a 5% holding held 12 months in a subsidiary resident in an EU/EEA or treaty state

«at least five per cent of the ordinary share capital of the relevant subsidiary. This is referred to as a qualifying participation. This must be held for a continuous period of at least 12 months. This period must include the date the relevant distribution is made. What is a relevant subsidiary? On the date a company makes a relevant distribution, that company must be: resident for foreign tax purposes in a relevant territory, and not generally exempt from foreign tax. The company must also have met the above conditions throughout the preceding five years, for relevant distributions made during 2025. For relevant distributions made from 1 January 2026, the company must have been, throughout the preceding three ye»

Source: revenue.ie · source copy as of 2026-10-03

«From 2026, a "relevant territory" includes a non-treaty country that generally applies a withholding tax on cross-border distributions. This withholding tax must be imposed at a nominal rate greater than zero per cent. The exemption only applies to a distribution from a non-treaty country where withholding tax is: paid on the full amount of the distribution and not refunded. What distributions qualify for exemption? A relevant distribution is a distribution made in respect of a relevant subsidiary's share capital. The distribution can be made out of the profits of the relevant subsidiary. Alternatively, the distribution can be made out of other assets of the relevant subsidiary. This is provided that»

Source: revenue.ie · source copy as of 2026-10-03

«at least 12 months. This period must include the date the relevant distribution is made. What is a relevant subsidiary? On the date a company makes a relevant distribution, that company must be: resident for foreign tax purposes in a relevant territory, and not generally exempt from foreign tax. The company must also have met the above conditions throughout the preceding five years, for relevant distributions made during 2025. For relevant distributions made from 1 January 2026, the company must have been, throughout the preceding three years: Irish tax resident or resident for foreign tax purposes in a relevant territory and not generally exempt from foreign tax. A relevant territory is an EU or EEA country»

Source: revenue.ie · source copy as of 2026-10-03

Applies when: capital gains; company (legal entity)

Exempt: 5% held 12 months in prior two years, trading test (s. 626B)

Gain on selling the subsidiary

«trading requirement. Shareholding Requirement The investor company must be, or have been, a parent (as defined in section 626B (1)(b)(i)) of the investee company. To qualify for exemption the disposal must either:  have taken place when the investor company was a parent of the investee company. (An investor company is regarded as a parent company of an investee company at any time if that time is within a continuous period of 12 months throughout which the investor has a “real” holding of at least 5 per cent of the investee company), or  have taken place within 2 years of the most recent time that the investor»

Source: revenue.ie · source copy as of 2026-10-03

«at least 5 per cent of the investee company), or  have taken place within 2 years of the most recent time that the investor company was a parent of the investee company. Residence Requirement The investee company must be resident in a relevant territory, i.e. an EU Member State, a territory with which Ireland has a double tax treaty in force or a territory with which Ireland has signed a double tax treaty which has yet to come into force. Trading Requirement At the time of the disposal of shares a trading condition must be met. This trading requirement can be satisfied by either the investee company or the gr»

Source: revenue.ie · source copy as of 2026-10-03

«12 months throughout which the investor has a “real” holding of at least 5 per cent of the investee company), or  have taken place within 2 years of the most recent time that the investor company was a parent of the investee company. Residence Requirement The investee company must be resident in a relevant territory, i.e. an EU Member State, a territory with which Ireland has a double tax treaty in force or a territory with which Ireland has signed a double tax treaty which has yet to come into force. Trading Requirement At the time of the disposal of shares a trading condition must be met. This trading requirement can be satisfied»

Source: revenue.ie · source copy as of 2026-10-03

Applies when: dividends and profit distributions; company (legal entity)

5% for 12 months; payer in EU/EEA/treaty state (s. 831B, from 2025; widened from 2026)

Dividend exemption: threshold / holding

«at least five per cent of the ordinary share capital of the relevant subsidiary. This is referred to as a qualifying participation. This must be held for a continuous period of at least 12 months. This period must include the date the relevant distribution is made. What is a relevant subsidiary? On the date a company makes a relevant distribution, that company must be: resident for foreign tax purposes in a relevant territory, and not generally exempt from foreign tax. The company must also have met the above conditions throughout the preceding five years, for relevant distributions made during 2025. For relevant distributions made from 1 January 2026, the company must have been, throughout the preceding three ye»

Source: revenue.ie · source copy as of 2026-10-03

«From 2026, a "relevant territory" includes a non-treaty country that generally applies a withholding tax on cross-border distributions. This withholding tax must be imposed at a nominal rate greater than zero per cent. The exemption only applies to a distribution from a non-treaty country where withholding tax is: paid on the full amount of the distribution and not refunded. What distributions qualify for exemption? A relevant distribution is a distribution made in respect of a relevant subsidiary's share capital. The distribution can be made out of the profits of the relevant subsidiary. Alternatively, the distribution can be made out of other assets of the relevant subsidiary. This is provided that»

Source: revenue.ie · source copy as of 2026-10-03

«at least 12 months. This period must include the date the relevant distribution is made. What is a relevant subsidiary? On the date a company makes a relevant distribution, that company must be: resident for foreign tax purposes in a relevant territory, and not generally exempt from foreign tax. The company must also have met the above conditions throughout the preceding five years, for relevant distributions made during 2025. For relevant distributions made from 1 January 2026, the company must have been, throughout the preceding three years: Irish tax resident or resident for foreign tax purposes in a relevant territory and not generally exempt from foreign tax. A relevant territory is an EU or EEA country»

Source: revenue.ie · source copy as of 2026-10-03

Resident if centrally managed and controlled in Ireland

Incorporated abroad

«on or after 1 January 2015. This will apply unless it is treated as a tax resident company in another country under a Double Taxation Agreement . If a company was incorporated before 1 January 2015, there is a transition period up to 31 December 2020. From this date, a company will be deemed to be tax resident unless it is tax resident in another country under a Double Taxation Agreement. There is an exception to this rule if, after 31 December 2014, a company has both: a change of ownership and a major change in the nature and conduct of the business. In these circumstances, the company will be tax resident from the date of the change in ownership. Before these rules were introduced, the central management and contr»

Source: revenue.ie · source copy as of 2026-10-03

«Double Taxation Agreement . If a company was incorporated before 1 January 2015, there is a transition period up to 31 December 2020. From this date, a company will be deemed to be tax resident unless it is tax resident in another country under a Double Taxation Agreement. There is an exception to this rule if, after 31 December 2014, a company has both: a change of ownership and a major change in the nature and conduct of the business. In these circumstances, the company will be tax resident from the date of the change in ownership. Before these rules were introduced, the central management and control rule was used to decide if a company was resident. A company was regarded as resident if its central management an»

Source: revenue.ie · source copy as of 2026-10-03

«central management and control rule was used to decide if a company was resident. A company was regarded as resident if its central management and control was performed in Ireland. This was the case whether the company was incorporated in Ireland or not. This rule will continue to apply, on a transitional basis, to Irish companies that were incorporated before 1 January 2015. Rules for companies that are not incorporated in Ireland The central management and control rule applies to foreign incorporated companies. If a company is incorporated in a foreign country and is centrally managed and controlled in Ireland, it is resident in Ireland for tax purposes. The central management and control test Revenue will consider the»

Source: revenue.ie · source copy as of 2026-10-03

«31 December 2020. From this date, a company will be deemed to be tax resident unless it is tax resident in another country under a Double Taxation Agreement. There is an exception to this rule if, after 31 December 2014, a company has both: a change of ownership and a major change in the nature and conduct of the business. In these circumstances, the company will be tax resident from the date of the change in ownership. Before these rules were introduced, the central management and control rule was used to decide if a company was resident. A company was regarded as resident if its central management and control was performed in Ireland. This was the case whether the company was incorporated in Ireland or no»

Source: revenue.ie · source copy as of 2026-10-03