The Finance Bill, 1999 proposes to render all Irish incorporated companies tax resident in Ireland. This will apply to all companies incorporated on or after 11th February 1999, and to companies incorporate before that date as on and from 1st October, 1999. There are certain exceptions to this general rule.
An Irish incorporated company which is resident in a treaty company for the purposes of the treaty between that country and Ireland, and which is not resident in Ireland will continue to be regarded as not resident in Ireland.
A second category of exemption exists to facilitate the use of Irish incorporated non-resident companies in structures adopted by multinationals investing in Ireland.