Ireland: Ireland As A Base For High Net Worth Individuals


Ireland is the European jurisdiction of choice for corporate entities, including securitisation companies and investment funds. It is also the world's leading jurisdiction for aircraft finance and leasing. What is less well known is that Ireland's tax system has the key features and flexibility to be an ideal base for high net worth individuals ("HNWIs") and senior foreign executives in multinationals and financial institutions. Moreover Ireland boasts superb infrastructure, air connections, a first class education system and a mature residential property market, all of which are important considerations for someone basing themself in Ireland.

The Irish rules regarding residence and domicile are similar to, yet far simpler than, many other jurisdictions, including the UK. The UK is introducing changes which will impact long term non-domiciled residents of the UK ("non-doms"). Ireland offers a potential solution to UK non-doms who are going to be affected by these changes (coming into effect in April 2017) as well as other HNWIs who are looking for an attractive place to live and to benefit from clear tax rules that will assist them in managing their wealth.

This article explains the rules and advantages of Irish non-domiciled status for qualified HNWIs.

Ireland's Non-Dom Tax Regime

Like the UK, Ireland has the concept of domicile as well as residence. Broadly, a non-domiciled Irish tax resident individual is subject to tax on income from Irish sources only. Foreign income and gains are only taxable to the extent of amounts remitted to Ireland ("remittance basis").

The UK's Non-Dom Tax Regime

Similar to Ireland, the remittance basis for UK income taxation applies to UK non-doms. However, in the UK. non-doms are subject to a regime of variable charges after specified periods of residence.

Broadly, those UK non-doms who have been resident in the UK for at least seven of the previous nine years must thereafter pay an annual charge of £30,000 if they choose to be taxed under the remittance basis regime. Those resident for 12 of the previous 14 years must pay £60,000 and those resident for 17 of the previous 20 years must pay £90,000.

There are no such charges levied in Ireland.

UK Changes

Changes were introduced in the 2015 Summer Budget which will affect many UK long term non-doms.

Non-dom status for long term residents is to be abolished. From April 2017 anyone who has been resident in the UK for more than 15 of the last 20 tax years will be deemed domiciled in the UK for all tax purposes.  They will be subject to UK tax on their worldwide income and gains on an arising basis and to UK inheritance tax on their worldwide assets.  A UK non-dom will have to become non-UK resident for at least five complete tax years to lose this deemed domiciled status.

The UK government has clarified that only gains arising and accruing on their offshore assets after 5 April 2017 will be subject to capital gains tax ("CGT") under this new deemed domicile regime.

Another change that has been introduced is that individuals with a UK domicile of origin will no longer be able to claim non-dom status while they are resident in the UK. They will be treated as UK domiciled for all tax purposes as soon as they become UK tax resident again.


The UK changes will pose difficulties for HNWIs who have been long-term residents of the UK, who will need to consider their options if they wish to avoid the consequences of deemed UK domicile status.  Ireland should be considered as a potential solution.

Both systems would have to be navigated together when planning to exit the UK. For example, when a UK non-dom becomes deemed domiciled after 15 years of residence, it takes five years of non-residence to lose this status. An individual can reside in Ireland for five years before they become subject to capital acquisitions tax ("CAT") (a tax on gifts and inheritance).

As noted, the Irish non-dom regime can also be of benefit to Irish non-dom senior executives relocating to the Irish operations of multinationals and financial institutions. While they do not benefit from the remittance basis on Irish source employment income, they may be able to obtain relief from income tax through the Special Assignee Relief Programme.

Ireland - Residence and Domicile

The Irish rules with regard to residence are much simpler than those in the UK and are based exclusively on a definitive "number of days" test.

An individual is regarded as tax resident in Ireland for a tax year if:

(a) they spend more than 183 days in Ireland in the tax year or;

(b) broadly, they spend over 280 days in Ireland over two consecutive years.

An individual can also elect to be a tax resident in Ireland, provided the Revenue Commissioners are satisfied they will meet these same minimum residence requirements in the following tax year.

By contrast, the UK rules around residence are more complex and a revised statutory residence test has been in effect since April 2013. This test takes into account a variety of factors such as the amount of "ties" an individual has to the UK including accommodation, employment and family relationships.

The concept of "domicile" is also of crucial importance because if an individual is not domiciled in Ireland they are not taxed on foreign income and gains unless they are remitted to Ireland.

There is no statutory definition of domicile under Irish law; it is a common law legal concept and the basic principles are the same in the UK.  Every individual is born with a domicile of origin. It is possible for a person to lose their domicile of origin and acquire a domicile of choice or to lose their domicile of choice and revive their domicile of origin.

Finally, in Ireland there is relief from CAT provided for non-doms in certain circumstances. The relief provides that although an individual may be tax resident in a given year for income or CGT purposes, they will only be treated as tax  resident for CAT purposes where they have been tax resident for the five previous tax years, prior to the year of assessment in which the gift or inheritance arises. This statutory test gives non-Irish domiciled individuals certainty as regards the CAT position and an ability to manage their arrangements.

Residency Permissions

In broad terms, any EU citizen may reside in Ireland. There are also a number of residency programmes operated by the Irish authorities to facilitate the acquisition of Irish residence by non-EEA citizens. The EEA is the European Union, plus Norway, Lichtenstein and Iceland.

The Immigrant Investor Programme is open to non-EEA nationals and their families who commit to an approved investment in Ireland. Approved participants in the programme and their immediate family members are granted rights of residence in Ireland which allows them to enter the state on multi-entry visas and to remain there for a defined period with the possibility of ongoing renewal. The programme allows participants, over time, to establish a permanent relationship with Ireland and to acquire residency status.

The Start-up Entrepreneur Programme is another available programme that allows non-EEA individuals and nominated family members to be resident in Ireland, provided they have an innovative business proposal and funding or financial backing of at least €75,000. This programme further provides for multi-entry visas, if required.

Attractions of Living in Ireland for HNWIs

Apart from the favourable tax regime for Irish non-dom residents there are a number of other attractions to living in Ireland.  Ireland is a safe and stable EU country and is the only Eurozone country where English is the principal language.

Ireland's infrastructure and air connections are well developed. There are international airports in Dublin, Belfast, Derry, Shannon and Cork and regional airports in Donegal, Galway, Kerry, Knock, Sligo and Waterford (which operate some international routes).  Most European cities are easily accessible within two to three hours flying time, whilst London is reachable within one hour. Ireland also has an excellent motorway network linking the major population centres.

Ireland has a first rate education system and is home to two of the top 150 universities in the world. It also has a world-class private healthcare system.

The Irish property market is vast and varied, from prestigious country estates to luxury city centre apartments, and offers greater value for money compared to other European countries.

Pre-entry Structuring

Before taking up residence in Ireland an individual would need to carefully consider the steps required both to break their existing residence and to become Irish resident. There is also important pre-entry tax structuring such as establishing segregated bank accounts.  This would be undertaken to ensure that income and gains realised before an individual moves to Ireland can be remitted to Ireland tax efficiently once they become Irish resident. Accordingly, it is important that legal and tax advice is taken well in advance of moving, which would include creating step plans and statements of affairs.

UK resident non-doms affected by the new deemed domicile rules have a window from now until 6 April 2017 in which they can avoid becoming UK domiciled by taking up residence in Ireland. Such individuals could enjoy the same benefits of non-dom status as they enjoyed in the UK.

Each individual case requires careful consideration of its own unique circumstances. Once these circumstances have been successfully navigated Ireland can prove itself as an excellent base for HNWIs.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

To print this article, all you need is to be registered on

Click to Login as an existing user or Register so you can print this article.

William Fogarty
In association with
Related Video
Up-coming Events Search
Font Size:
Mondaq on Twitter
Register for Access and our Free Biweekly Alert for
This service is completely free. Access 250,000 archived articles from 100+ countries and get a personalised email twice a week covering developments (and yes, our lawyers like to think you’ve read our Disclaimer).
Email Address
Company Name
Confirm Password
Mondaq Topics -- Select your Interests
 Law Performance
 Law Practice
 Media & IT
 Real Estate
 Wealth Mgt
Asia Pacific
European Union
Latin America
Middle East
United States
Worldwide Updates
Mondaq Ltd requires you to register and provide information that personally identifies you, including what sort of information you are interested in, for three primary purposes:
  • To allow you to personalize the Mondaq websites you are visiting.
  • To enable features such as password reminder, newsletter alerts, email a colleague, and linking from Mondaq (and its affiliate sites) to your website.
  • To produce demographic feedback for our information providers who provide information free for your use.
  • Mondaq (and its affiliate sites) do not sell or provide your details to third parties other than information providers. The reason we provide our information providers with this information is so that they can measure the response their articles are receiving and provide you with information about their products and services.
    If you do not want us to provide your name and email address you may opt out by clicking here
    If you do not wish to receive any future announcements of products and services offered by Mondaq you may opt out by clicking here

    Terms & Conditions and Privacy Statement (the Website) is owned and managed by Mondaq Ltd and as a user you are granted a non-exclusive, revocable license to access the Website under its terms and conditions of use. Your use of the Website constitutes your agreement to the following terms and conditions of use. Mondaq Ltd may terminate your use of the Website if you are in breach of these terms and conditions or if Mondaq Ltd decides to terminate your license of use for whatever reason.

    Use of

    You may use the Website but are required to register as a user if you wish to read the full text of the content and articles available (the Content). You may not modify, publish, transmit, transfer or sell, reproduce, create derivative works from, distribute, perform, link, display, or in any way exploit any of the Content, in whole or in part, except as expressly permitted in these terms & conditions or with the prior written consent of Mondaq Ltd. You may not use electronic or other means to extract details or information about’s content, users or contributors in order to offer them any services or products which compete directly or indirectly with Mondaq Ltd’s services and products.


    Mondaq Ltd and/or its respective suppliers make no representations about the suitability of the information contained in the documents and related graphics published on this server for any purpose. All such documents and related graphics are provided "as is" without warranty of any kind. Mondaq Ltd and/or its respective suppliers hereby disclaim all warranties and conditions with regard to this information, including all implied warranties and conditions of merchantability, fitness for a particular purpose, title and non-infringement. In no event shall Mondaq Ltd and/or its respective suppliers be liable for any special, indirect or consequential damages or any damages whatsoever resulting from loss of use, data or profits, whether in an action of contract, negligence or other tortious action, arising out of or in connection with the use or performance of information available from this server.

    The documents and related graphics published on this server could include technical inaccuracies or typographical errors. Changes are periodically added to the information herein. Mondaq Ltd and/or its respective suppliers may make improvements and/or changes in the product(s) and/or the program(s) described herein at any time.


    Mondaq Ltd requires you to register and provide information that personally identifies you, including what sort of information you are interested in, for three primary purposes:

    • To allow you to personalize the Mondaq websites you are visiting.
    • To enable features such as password reminder, newsletter alerts, email a colleague, and linking from Mondaq (and its affiliate sites) to your website.
    • To produce demographic feedback for our information providers who provide information free for your use.

    Mondaq (and its affiliate sites) do not sell or provide your details to third parties other than information providers. The reason we provide our information providers with this information is so that they can measure the response their articles are receiving and provide you with information about their products and services.

    Information Collection and Use

    We require site users to register with Mondaq (and its affiliate sites) to view the free information on the site. We also collect information from our users at several different points on the websites: this is so that we can customise the sites according to individual usage, provide 'session-aware' functionality, and ensure that content is acquired and developed appropriately. This gives us an overall picture of our user profiles, which in turn shows to our Editorial Contributors the type of person they are reaching by posting articles on Mondaq (and its affiliate sites) – meaning more free content for registered users.

    We are only able to provide the material on the Mondaq (and its affiliate sites) site free to site visitors because we can pass on information about the pages that users are viewing and the personal information users provide to us (e.g. email addresses) to reputable contributing firms such as law firms who author those pages. We do not sell or rent information to anyone else other than the authors of those pages, who may change from time to time. Should you wish us not to disclose your details to any of these parties, please tick the box above or tick the box marked "Opt out of Registration Information Disclosure" on the Your Profile page. We and our author organisations may only contact you via email or other means if you allow us to do so. Users can opt out of contact when they register on the site, or send an email to with “no disclosure” in the subject heading

    Mondaq News Alerts

    In order to receive Mondaq News Alerts, users have to complete a separate registration form. This is a personalised service where users choose regions and topics of interest and we send it only to those users who have requested it. Users can stop receiving these Alerts by going to the Mondaq News Alerts page and deselecting all interest areas. In the same way users can amend their personal preferences to add or remove subject areas.


    A cookie is a small text file written to a user’s hard drive that contains an identifying user number. The cookies do not contain any personal information about users. We use the cookie so users do not have to log in every time they use the service and the cookie will automatically expire if you do not visit the Mondaq website (or its affiliate sites) for 12 months. We also use the cookie to personalise a user's experience of the site (for example to show information specific to a user's region). As the Mondaq sites are fully personalised and cookies are essential to its core technology the site will function unpredictably with browsers that do not support cookies - or where cookies are disabled (in these circumstances we advise you to attempt to locate the information you require elsewhere on the web). However if you are concerned about the presence of a Mondaq cookie on your machine you can also choose to expire the cookie immediately (remove it) by selecting the 'Log Off' menu option as the last thing you do when you use the site.

    Some of our business partners may use cookies on our site (for example, advertisers). However, we have no access to or control over these cookies and we are not aware of any at present that do so.

    Log Files

    We use IP addresses to analyse trends, administer the site, track movement, and gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information.


    This web site contains links to other sites. Please be aware that Mondaq (or its affiliate sites) are not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of these third party sites. This privacy statement applies solely to information collected by this Web site.

    Surveys & Contests

    From time-to-time our site requests information from users via surveys or contests. Participation in these surveys or contests is completely voluntary and the user therefore has a choice whether or not to disclose any information requested. Information requested may include contact information (such as name and delivery address), and demographic information (such as postcode, age level). Contact information will be used to notify the winners and award prizes. Survey information will be used for purposes of monitoring or improving the functionality of the site.


    If a user elects to use our referral service for informing a friend about our site, we ask them for the friend’s name and email address. Mondaq stores this information and may contact the friend to invite them to register with Mondaq, but they will not be contacted more than once. The friend may contact Mondaq to request the removal of this information from our database.


    From time to time Mondaq may send you emails promoting Mondaq services including new services. You may opt out of receiving such emails by clicking below.

    *** If you do not wish to receive any future announcements of services offered by Mondaq you may opt out by clicking here .


    This website takes every reasonable precaution to protect our users’ information. When users submit sensitive information via the website, your information is protected using firewalls and other security technology. If you have any questions about the security at our website, you can send an email to

    Correcting/Updating Personal Information

    If a user’s personally identifiable information changes (such as postcode), or if a user no longer desires our service, we will endeavour to provide a way to correct, update or remove that user’s personal data provided to us. This can usually be done at the “Your Profile” page or by sending an email to

    Notification of Changes

    If we decide to change our Terms & Conditions or Privacy Policy, we will post those changes on our site so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If at any point we decide to use personally identifiable information in a manner different from that stated at the time it was collected, we will notify users by way of an email. Users will have a choice as to whether or not we use their information in this different manner. We will use information in accordance with the privacy policy under which the information was collected.

    How to contact Mondaq

    You can contact us with comments or queries at

    If for some reason you believe Mondaq Ltd. has not adhered to these principles, please notify us by e-mail at and we will use commercially reasonable efforts to determine and correct the problem promptly.

    By clicking Register you state you have read and agree to our Terms and Conditions