This article was originally published in the BKR International EMEA Update, released 14th March 2024. Written by: John Conway BBS AITI CTA, Partner and Tax Specialist, Ormsby & Rhodes.
IRELAND – A DESTINATION FOR NON-DOMS
The recent announcement that the UK is to severely restrict its ‘Non-Dom’ regime has led many UK based ‘Non-Doms’ to start the search for alternative destinations. Non-Dom, according to www.gov.uk describes UK residents who have their permanent home (‘domicile’) outside the UK and therefore they may not have to pay UK tax on foreign income.
Countries high on the list of UK alternatives may include Italy, Spain, Malta, Singapore and Ireland.
Ireland may attract many of the UK based ‘Non-Doms’ due to its proximity and its similar tax regime for ‘Non-Doms’.
The UK has historically been an attractive location for ‘Non-Doms’ to relocate to for many reasons. The tax regime was favourable but also the UK is a world heavyweight in many economic and financial activities, particularly the financial sector based around the City of London. As a result, many global wealthy individuals relocated to the UK and benefitted from its ‘Non-Dom’ tax regime.
Ireland has a ‘Non-Dom’ tax regime similar to the one that operated in the UK. In fact, the Irish ‘Non-Dom’ regime is arguably more advantageous to that of the UK. Unlike the UK, Ireland does not have a time limit and therefore it does not impose a “deemed-domicile” rule after a certain number of years. There is also no annual charge for ‘Non-Doms’ and no application or formal qualification process.
Ireland has in recent decades also been a popular location for entrepreneurs and high net-worth individuals to relocate to. The booming tech and pharma sectors in Ireland meant that many foreign executives have located in Ireland and the Irish ‘Non-Dom’ regime has benefitted these individuals along with other tax reliefs such as SARP (Special Assignee Relief Programme).
It is relatively straightforward to become a ‘Non-Dom’ in Ireland and avail of the remittance basis of taxation. If an individual plans in advance it may also be possible to bring “capital” funds into Ireland tax free.
Like other jurisdictions, Ireland is keeping its ‘Non-Dom’ regime under review, however, in its current format it is bound to be a consideration for many UK based individuals who may be affected by its recent restriction on its Non-Dom regime.
If you have any queries in respect to becoming a ‘Non-Dom’ in Ireland, contact our Tax specialists here at Ormsby & Rhodes by emailing info@ormsby-rhodes.ie.