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Tax Treaties: United States And Ireland



Tax Treaties: United States And Ireland

Quick Summary.  Ireland is a parliamentary democracy based on the 1937 Constitution of Ireland.  The Irish parliament is divided into two houses, the house of representatives (Dáil Éireann) and a senate (Seanad Éireann).

Effective 2019, Ireland has ratified the OECD’s Multilateral Instrument.  In addition, effective 2019, Ireland has implemented controlled foreign corporation (CFC) rules effectuating provisions set out in the European Union’s (EU’s) Anti-Tax Avoidance Directive (ATAD).  Ireland has Also implemented exit tax rules.

Ireland taxes resident corporations on worldwide profits; non-resident companies are subject to tax on certain Irish-source income.

Resident/domiciliary individuals are taxed on worldwide income; whereas, residents not domiciled in Areas are taxed on certain Irish-source income and foreign income remitted into Ireland.  Non-residents are generally subject to tax only on Irish-source income.

Treaty.

Currency.  Euro (EUR)

Common Legal Entities.  Public and private limited liability company, partnership, sole proprietorship, and branches.

Tax Authority.  Office of the Revenue Commissioners

Tax Treaties.  Ireland is party to the OECD’s MLI.  

Corporate Income Tax Rate.  12.5% – 25%.

Individual Tax Rate. Up to 40%.

Corporate Capital Gains Tax Rate.  33% -44%.

Individual Capital Gains Tax Rate. 33% -44%.

Residence.  Individual residence is established where an individual spends more than 183 days during the tax year in Ireland or has 280 days of combined presence over the tax year and preceding year.

Withholding Tax.

            Dividends.  0% / 25%

            Interest.  0% / 20% / 33%

            Royalties.  0% / 20%

Transfer Pricing.  Ireland employs the arm’s length principle.  

CFC Rules.  CFC rules are applicable as of January 1, 2019.

Hybrid Treatment.  Effective January 1, 2020, Anti hybrid rules in line with ATAD 2 are applicable.   

Participation Exemption.  Yes.

Have a question? Contact Jason Freeman, Freeman Law.

Jason Freeman

Mr. Freeman is the founding and managing member of Freeman Law, PLLC. He is a dual-credentialed attorney-CPA, author, law professor, and trial attorney. Mr. Freeman has been recognized multiple times by D Magazine, a D Magazine Partner service, as one of the Best Lawyers in Dallas, and as a Super Lawyer by Super Lawyers, a Thomson Reuters service.
He was honored by the American Bar Association, receiving its “On the Rise – Top 40 Young Lawyers” in America award, and recognized as a Top 100 Up-And-Coming Attorney in Texas. He was also named the “Leading Tax Controversy Litigation Attorney of the Year” for the State of Texas” by AI.

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