On Tuesday 14 February, the Irish government announced the closure of the Immigrant Investor Programme (IIP). IIP applications via approved projects may be granted a grace period of three months to submit the finalised application. Any interest in IIP is the last chance and would have to apply on an urgent and immediate basis or the programme will no longer be available. Contact us now.

Ireland versus the UK: how taxes compare for immigrants

Given the unique connection between the UK and Ireland, people often like to compare the two countries, from economic development to various aspects of living. And taxes have, of course, been much talked about, particularly among immigrants. Here, we discuss the fundamental tax implications for those looking to move to either Ireland or the UK.

What exactly is the relationship between the two countries? The UK and Ireland have benefitted from the Common Travel Area arrangement since 1922 and those born in Northern Ireland have rights to take up both Irish and British citizenship. Ireland is also unique among EU countries in that it shares a land border with the UK. Moving between countries and residing for a period of time in one or the other, individuals or families are liable to taxes under different tax regimes. Broadly speaking, there are eight major tax considerations:

1. Income Tax
2. Universal Social Charge (USC) Ireland / Social Security Rate and the Health and Social Care Levy in UK
3. Pay Related Social Insurance (PRSI) Ireland / National Insurance Contributions (NICs) in UK
4. Capital Gains Tax (CGT)
5. Capital Acquisitions Tax (CAT)
6. Value Added Tax (VAT)
7. Stamp Duty
8. Corporation Tax

In our recent Immigration Insights video, our Sales Manager Tanya Wong spoke to Helen Lau, a member of the Association of Chartered Certified Accountants in the UK and The Hong Kong Institute of Certified Public Accountants and a Hong Kong-certified Tax Advisor on UK and Irish taxes, including various tax reliefs and different concepts of domicile between the countries. Click to watch the video.

There are a few important points worth highlighting to distinguish between Ireland and UK taxes for immigrants.

State of domicile

Domicile of Origin usually relates to where you were born, while there is a Domicile of Choice if an individual moves to a country where he or she has decided to settle permanently.

There is also the concept of Deemed Domicile in the UK – individuals who have been UK residents for at least 15 out of the previous 20 tax years are deemed domiciled. Unlike the UK, there are no ‘deemed domicile’ rules in Ireland, making Ireland more favourable to non-domiciled individuals from a tax perspective. “Ireland’s number of non-domiciled individuals increased from 3,393 in 2013 to 7,262 in 2016. This has been driven in part by executives employed at multinational companies moving in and also by the take-up of the Irish Immigrant Investor Programme,” said Helen.

Individuals who become tax residents in Ireland and are non-domiciled, will only be taxed on their Ireland-sourced income and gains, and their worldwide income and gains only to the extent that they are brought into Ireland under Ireland’s non-domicile regime. A non-domicile status can continue indefinitely. In addition, Ireland has a comprehensive double taxation treaty network that a non-domiciled but tax resident individual can rely on.

Tax reliefs

With regard to the remittance basis of tax, Ireland is more favourable than the UK. Foreign nationals who become Irish tax residents, but are not Irish domiciled, will be taxed on a ‘remittance basis’. This means that they are taxed in Ireland on Irish employment income, Irish source income and non-Irish source income only to the extent they remit it to Ireland. There are very few countries that have this favourable tax treatment.

On the Double Tax Agreement (DTA), both Ireland and the UK are under the Comprehensive Double Taxation Agreements (CDTA) with Hong Kong, and the rates are similar. The maximum rates of withholding under the HK-Ireland Double Treaty on dividends is reduced to 0%; 10% for interest, or 0% in certain circumstances; 3% for royalties. Under the HK-UK Double Treaty, the withholding tax on dividends is reduced to 0% in some cases or 15% in others (the non-treaty rate is 20%); 0% for interest; 3% for royalties.

In Ireland, there is also the Special Assignee Relief Programme (SARP), which is a tax incentive used to attract talent (including returning Irish nationals) from outside Ireland to work in Ireland. The relief operates by allowing a 30% deduction from any employment income in excess of €75,000.

For other tax-related information, read our previously published articles:


For families who are thinking of moving to the UK or Ireland, it is important to understand any obligations for taxes at the different stages of immigration. One of the benefits of the IIP is that it allows families to have less pressure on tax planning due to its residing flexibility and offers plenty of time to sort out taxes before becoming tax residents.

Practical tips on Irish tax to get your finances in order before moving to Ireland

Compared to many English-speaking countries, Ireland has comparatively favourable tax regimes for immigrants, but the key to tax efficiency is always good planning to ensure your finances are in order before you arrive in the country.

In our previous blog Tax 101 – a simple tax guide for immigrants to Ireland, we went through the major Irish taxes that IIP investors should be aware of. To help you further understand the tax implications that might accompany a move to Ireland, our Marketing Director, Jay Cheung, spoke to Gabriel Ho, Director of People Services at KPMG for the latest episode of Immigration Insights with Bartra Wealth Advisors. Watch the video for insights on tax-related considerations and actions to take before moving to Ireland.

Residence for Tax Purposes

“As a starting point, consider the amount of time you anticipate spending in Ireland and plan your finances before moving to Ireland. This can significantly impact your Ireland tax position and tax liabilities,” says Gabriel.

The tax liability of an individual in Ireland is determined by whether they are resident in the country and whether they are domiciled in Ireland. According to the Revenue Commissioners, the Irish Tax and Customs agency, your tax residence status depends on the number of days you are present in Ireland during a tax year (the period from 1 January to 31 December). You are resident in Ireland for tax purposes if you are in Ireland for a total of:

  • 183 days or more in a tax year, or
  • 280 days or more in Ireland over two consecutive tax years, with a minimum of 30 days in each year

Tax residence is taken into account for several taxes including income tax, inheritance tax and capital gains tax (CGT). It is worth noting that you will become ordinarily resident if you have been resident in Ireland for 3 consecutive tax years. An individual who is ordinarily resident in Ireland is liable to Irish taxes regardless of the number of days spent in Ireland, until being non-resident for another 3 consecutive tax years.

The Irish Immigrant Investor Programme (IIP) offers extensive flexibility to its investors as the minimum stay is only one day per year. Investors can decide whether to become a tax resident in Ireland depending on their situation.


Remittance Basis

The remittance basis of tax is advantageous to people coming into Ireland if non-domiciled. If not an Irish national, then any investment income is only taxable if you bring it into Ireland.

The remittance basis is very attractive in bringing people to Ireland, as for most IIP applicants, their income is in overseas investments. There are very few countries that offer this favourable tax treatment.

It is important to understand what constitutes an Irish source of income and what is not an Irish source of income. For instance, investors might bring their income into Ireland before they arrive, so-called ‘clean capital’ that is income earned while not resident in Ireland. This money has generally already been taxed overseas and is not from an Irish source. “In general, if you would like to dispose of assets before you move, we suggest you do so at least one year before becoming tax residents in Ireland. The gain should not be subject to Ireland tax even if you remit the proceeds to Ireland at a later time,” says Gabriel.

For example, if an individual who will move to and become tax resident in Ireland in 2022 disposes assets on or before 31 December 2021, the gain should not be subject to Ireland tax even if they remit the proceeds to their Ireland bank account in 2021 or later. If you earn overseas investment income while resident in Ireland, as long as you do not bring the funds into Ireland then Irish Revenue will not seek to tax it.

There is also the Special Assignee Relief Programme (SARP), which is a tax incentive used to attract talent from outside Ireland to work in Ireland. If a person meets the conditions of SARP they enjoy a preferential tax rate on employment income where the income tax rate that applies is 28%.

Tax family

Planning Ahead

It is crucial to plan early to achieve the best tax benefits. Try to create a clear list of your assets and investment portfolio that you disclose to your financial or tax advisor in order to assess whether it will be considered clean capital and if it is possible to remit it to Ireland without incurring any additional Irish taxes.

It is also important to document the income that is brought into Ireland and have any backup information to hand in the event of any enquiries from Irish Revenue. By not planning correctly regarding the source of the income you bring into Ireland or the timing of when you bring in this income you may become liable to additional taxes or scrutiny from Irish Revenue.

Gabriel says individuals may also consider having separate bank accounts in Ireland. “For example, one account for holding funds remitted to Ireland which should not be subject to tax, and another account for holding funds remitted to Ireland which may be subject to tax. This should help ring-fence income and gains which should not be subject to Ireland tax.”


Tax implication varies from family to family, and it is affected by a myriad of factors. However, IIP’s flexibility allows plenty of time for investors to properly plan their finances before relocating to Ireland. We hope that investors can mitigate unwanted tax spending after understanding how the Irish tax regime works.

Bartra Wealth Advisors prides itself on delivering streamlined, end-to-end services. Our unique business model supports clients throughout their investment and immigration journey, from immigration advisory and government-backed IIP projects through to exit executions. Contact us if you have any questions regarding Ireland’s tax regime or the IIP.

Disclaimer: Information correct as of 27 August 2021. Bartra Wealth Advisors and its affiliates provide individualised services to immigration. All information provided to investors and clients is with such purpose in mind. Should investors have any enquiries about any specific legal, tax or financial planning matter relating to their personal circumstances, Bartra Wealth Advisors recommends that investors seek independent professional advice. Although every care has been taken to ensure the accuracy of the information and contents of the materials, which are obtained from sources believed to be reliable, Bartra Wealth Advisors does not represent, warrant or guarantee the accuracy, completeness, timeliness, reliability or suitability of the information or contents for any particular purpose.

Tax 101 – a simple tax guide for immigrants to Ireland

Ireland is an attractive destination for immigration. As an English-speaking EU member state with a world-class education system, transparent and fair State structures, plenty of foreign investment, Ireland is seeing a rise in the number of high-net-worth foreigners seeking Irish residency.

Whether you are planning to move to Ireland permanently or you plan to obtain residency without moving thanks to the flexibility of the IIP, it is important to know what specific tax obligations come with your situation, and if there are actions you may need to take to get your tax affairs in order.

Planning your finances before you become liable for Irish taxes and understanding global income tax can save you a significant amount of money. Taxes can be expensive and burdensome, but there are ways to minimize your tax liability in a legal way.

Income Tax, Capital Gains Tax, Inheritance Tax and other taxes

An individual can only be regarded as an Irish tax resident for a given tax year if he or she spends 183 days or more in Ireland during the tax year, or 280 days or more in Ireland in the current tax year and the previous tax year combined. In other words, given the flexibility of IIP, which requires a minimum stay of just one day in a year, investors spending less than 183 days a year who are domiciled outside of Ireland would not be liable to Irish tax. It is worth noting that investors who stay in Ireland for more than 183 days in a tax year, as long as their earnings are not remitted into Ireland, they may not fall within the Irish income tax net. 

There are a variety of different taxes that individuals interested in Irish residency should be aware of. In our video series Immigration Insights with Bartra Wealth Advisors, Jay Cheung, Bartra’s Marketing Director spoke to Kenneth Yeung, a senior accountant and tax advisor from China Consulting Consortium about matters around income tax, capital gain tax, property tax and inheritance tax. Kenneth is a member of the Institute of Chartered Accountants in England and Wales and has been providing accounting and tax services to Chinese residents in the UK and Ireland for the past 30 years. To understand more about Irish tax, watch the episode now.

Income Tax

Personal tax varies and can be complicated. The reference guide below provides basic Irish tax information. Investors should always obtain independent tax advice. Worth noting is that in Ireland there are a large number of exemptions available depending on your type of income and whether the recipient of the income is resident in a country with which Ireland has a double tax treaty.

Income tax rates and rate bands

Irish Tax Eng

All individuals whose gross income exceeds the minimum threshold of €13,000 per annum are liable to pay the Universal Social Charge (USC). And most employers and employees (over 16 and under 66 years of age) pay social insurance (PRSI) contributions into the national Social Insurance Fund.

Personal income tax rates in Ireland are in line with other developed countries. For example, looking to Europe (the top rates), the income tax rate in Germany is 42%; the UK is 45%; France is 45%; Portugal is 48%; and the Netherlands is the world’s highest at 52%. Outside Europe and considering popular immigration countries, the rate in the US is 37%; 33% in Canada; 45% in Australia. China’s tax rate is 45%.

Capital Gains Tax (CGT)

The CGT rate in Ireland is 33% for most gains. However, there are other rates for specific types of gains:

  • 40% for gains from foreign life policies and foreign investment products
  • 15% for gains from venture capital funds for individuals and partnerships
  • 12.5% for gains from venture capital funds for companies

Again, for investors who spend less than 183 days a year in Ireland, they may not be taxable for either income or capital gains from other countries. 

Inheritance Tax

The thorn in the side of many an inheritance is the tax and in Ireland inheritance tax, or Capital Acquisitions Tax (CAT), is a hefty 33%. A child is entitled to inherit a certain amount (up to €310,000) tax-free, after which 33% is charged.

Other taxes

For those looking to run a business in Ireland, Corporate Income Tax and Value Added Tax (VAT) are the most important to know. In Ireland, corporate tax is 12.5%, one of the lowest in Europe and the normal VAT rate is 23%.

Tax Couple

Case study I: In what circumstances would I obtain Irish residency from the IIP and, although not domiciled in Ireland, still be liable to Irish income tax?

There are two types of income: employment income and investment income.

Employment income – you will be liable to Irish income tax on Irish employment income in full and non-Irish employment income to the extent that either your duties relate to Irish workdays or you remit your income relating to non-Irish workdays to Ireland.

Investment income – you are liable to Irish income tax on investment income from Irish sources. Investment income from other countries will not be taxable as long as the income is not remitted into the State. The remittance basis for a non-Irish domiciled individual continues regardless of residence/ ordinary residence status.

Case study II: When investing in nursing home projects, there is a 20% return from the 1million investment (4% per annum) upon maturity of the 5-year investment horizon. Is this 20% taxable to Ireland?

If you reside outside of Ireland and are not spending more than 183 days in Ireland, the 20% investment return from nursing home IIP projects is non-taxable to the State.


Bartra’s Northwood Nursing Home, completed and opened in Spring 2020, is home to 118 single occupancy private ensuite rooms.

Case study III: How would setting up a trust or having Life Insurance help with tax planning?

Some clients are keen to establish an “immigration trust”. The trust may hold cash deposits, shares in private and public companies, bonds, real estate and other types of investments, and provides an opportunity for immigrants to earn foreign investment income on a tax-free basis in the trust for a long period of time.

Clients may wish to consider using a trust for inheritance tax planning. As stated above, children are entitled to inherit up to €310,000 tax-free, after which 33% tax is charged. The assets in a trust are held in the name of a trustee but go directly to the beneficiary, who has a right to both the assets and income of the trust. Transfers into a bare trust may be exempt from inheritance tax.

Immigrants may also benefit from having a life insurance policy or a life insurance trust as the death benefit is typically tax-free. Beneficiaries generally don’t have to report the payout as income, making it a tax-free lump sum that they can employ freely, and potentially use to pay any required inheritance tax in order to receive the assets.


In conclusion, as is evident from the above, immigrants to Ireland can be subject to different tax treatments depending on how their wealth is structured. Great tax benefits can be achieved provided tax planning is in place. However, tax laws may change over time, so it is advisable to revisit your tax plan to avoid being unintentionally caught by any new tax laws and regulations.


Disclaimer: Information correct as of 19 February 2021. Bartra Wealth Advisors and its affiliates provide individualised services in relation to immigration. All information provided to investors and clients is with such purpose in mind. Should investors have any enquiries about any specific legal, tax or financial planning matter relating to their personal circumstances, Bartra Wealth Advisors recommends that investors seek independent professional advice. Although every care has been taken to ensure the accuracy of the information and contents of the materials, which are obtained from sources believed to be reliable, Bartra Wealth Advisors does not represent, warrant or guarantee the accuracy, completeness, timeliness, reliability or suitability of the information or contents for any particular purpose.