The Core Rules: How You Become an Irish Tax Resident
Your tax liability in Ireland hinges on whether you are considered a tax resident. The Irish tax year runs from January 1st to December 31st, and residency is determined by a simple day-counting test. There are two ways you can trigger tax residency:
The 183-Day Rule: This is the most straightforward test. If you spend 183 days or more in Ireland within a single tax year, you are considered an Irish tax resident for that year.
The 280-Day Rule (The "Look-Back" Test): This rule prevents you from spending just under six months in Ireland for two consecutive years to avoid residency. You will be considered a tax resident for the current year if you spend a combined total of 280 days or more in Ireland between the current tax year and the previous one. A key condition for this rule is that you must spend at least 30 days in Ireland in each of the two years.
The "Ordinary Residence" Trap for Long-Term Nomads
Beyond simple residency, Ireland has a concept called "ordinary residence." This is a longer-term status that can have significant tax implications. You become ordinarily resident in Ireland after being an Irish tax resident for three consecutive years. The status officially begins in the fourth year.
Why does this matter? An ordinarily resident individual can remain liable for Irish income tax on their worldwide investment income, even if they are no longer living in Ireland or meeting the 183/280 day tests. Losing this status is also a multi-year process, requiring you to be non-resident for three consecutive years. For nomads with investment portfolios, this is a critical rule to be aware of. In some cases, a Double Taxation Agreement (DTA) between Ireland and another country can override this domestic rule.
The Domicile Advantage: The "Remittance Basis" Hack
This is where Ireland becomes particularly interesting for international entrepreneurs. For tax purposes, your "domicile" is considered your permanent home, the country you ultimately belong to. It's a complex legal concept distinct from residency or citizenship.
Domicile of Origin: You acquire this at birth, typically from your father.
Domicile of Choice: You can acquire a new domicile as an adult by severing ties with your original domicile and demonstrating a clear intention to live in a new country permanently. This is notoriously difficult to prove.
For a non-Irish domiciled person who becomes an Irish tax resident, a powerful tax planning tool becomes available: the remittance basis of taxation. Under this system, you are only taxed on foreign-source income (like profits from your overseas US LLC) if you "remit" or bring that money into Ireland. Income earned and kept outside of Ireland remains outside the Irish tax net. This allows you to bring in funds for your living expenses while keeping your business profits tax-free in your home country or a third country.
Special Cases: Split-Year & Elective Residency
Two other concepts are worth noting, though they may apply to more specific situations:
Split-Year Residence Relief: This applies only to employment income. If you arrive in or depart from Ireland mid-year to start or leave a job, you can split the tax year. This means your employment income is only taxed from your date of arrival or up to your date of departure. This relief does not apply to business or investment income.
Electing to be Resident: If you arrive in Ireland and don't meet the day-count test for the current year but intend to be resident in the following year, you can elect to be treated as a tax resident for your arrival year. This can be beneficial for accessing personal tax credits that are otherwise unavailable to non-residents.
