• CORPORATION TAX

    CORPORATION TAX

    MALONE & CO.

    Ireland has for many years had a flat 12.5% corporate tax rate applicable to Irish trading profits. This has been augmented by the introduction of a 0% rate for new trading companies for the first three years of trading subject to certain conditions. There is a higher rate of corporation tax of 25% for non trading income such as rent.

    Corporation Tax in Ireland is charged on all profits, wherever arising, of companies resident in the State, and profits of non-resident companies in so far as those profits are attributable to an Irish branch or agency, unless certain exemptions and reliefs can be availed of.

    Ireland’s taxation system contains many incentives used in attracting overseas Investment to Ireland some of which make it easier to do business here. A common reason cited for locating business in Ireland has often been Ireland’s favourable corporate tax rate.

    Clearly Ireland continues to be committed to its favourable corporation tax regime. The standard rate applies to trading profits without limit, which has led to many multinational corporations locating here. It has also shown its commitment to low corporation tax by extending the 3 year start up exemption

    TAX PLANNING

    MALONE & CO.

    We work with clients to ensure important future transactions are properly planned from a tax minimization perspective on a range of areas such as deciding on buying or selling property, making investments, retiring from or selling a business, making a gift to an individual or family member. All of these events usually trigger a tax liability which can be minimised or avoided in a tax compliant manner in certain circumstances by proper advance tax planning. Some other areas we have significant expertise in include:

    • Tax efficient retirement planning
    • Transfer of a business to a company
    • Succession planning
    • Estate Planning

    Non-Residents, Expatriates & Non-Domiciliaries

    We work with overseas individuals to help mitigate their overall tax burden, including foreign taxes. In particular, we focus on devising strategies which minimise our client’s exposure to income tax and capital gains tax.

    Non-residents, Expatriates and non-Domiciliaries are subject to specific tax rules in Ireland which can assist them in tax planning for their future such as the remittance basis of tax. Ireland also has an extensive tax treaty network and frequently, expats and non-domiciliaries have to take account of the interaction between treaty countries and the implications it has for their tax affairs.

    INCOME TAX

    MALONE & CO.

    The extent of an individual’s liability to Irish income tax depends on:

    • whether he/she is tax resident in Ireland;
    • whether he/she is ordinarily tax resident in Ireland; and
    • whether he/she is domiciled in Ireland.

    Your residence status for tax purposes is determined by the number of days that you are present in Ireland in a tax year. You will be resident in Ireland for a tax year in either of the following circumstances:

    • If you spend 183 days or more in Ireland during a tax year or,
    • If you spend 280 days or more in Ireland over a period of two consecutive tax years, you will be regarded as resident for the second tax year. For example, if you spend 140 days here in Year 1 and 150 days here in Year 2, you will be resident in Ireland for Year 2.

    Income and gains from the period before an individual moves to Ireland can be brought in to Ireland entirely tax free. This can help fund any expenditure whilst based in Ireland tax efficiently. There are also various reliefs such as Split-year residence, Cross-border workers relief and Seafarers allowance which can minimise the exposure to the charge of Irish Income tax on a persons income.

    A new Special Assignee Relief Programme (SARP) was introduced in Finance Act 2012 is to assist multinational and Irish companies in attracting key high income talent into Ireland by reducing their level of taxable income here by up to 30%.

    As part of a measure to develop and promote Irish exports, recent Finance Acts have introduced an income tax relief called the Foreign Earnings Deduction (FED). The FED will apply to Irish tax resident individuals working in certain countries up to 2014. The relief operates by granting a tax deduction against the individual’s income tax liability where certain conditions are met.