1. Connection Factors
1.1 To what extent is domicile or habitual residence
relevant in determining liability to taxation in your
jurisdiction?
Domicile is a very significant connecting factor. Where an
individual is tax resident in Ireland
("State"), the addition of domicile as a
connecting factor will mean that all of the individual's
worldwide income and gains are subject to Irish tax, subject to any
reliefs under existing double tax treaties.
The concept of habitual residence does not exist in Ireland and
is not defined under Irish law.
1.2 If domicile or habitual residence is relevant, how
is it defined for taxation purposes?
There is no statutory definition of domicile under Irish tax
law, rather it is a legal concept. Pursuant to Irish law, 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
