ARTICLE · 14 JANUARY 2015

Changes To Irish Corporate Residence Rules

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On October 14 2014, Ireland's Minister for Finance announced changes to Ireland's corporate residence rules.

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On October 14 2014, Ireland's Minister for Finance (the Minister) announced changes to Ireland's corporate residence rules. Following much speculation, the Minister confirmed that Ireland would change its rules to restrict the ability of Irish incorporated companies to be treated as non-Irish resident.

Under existing Irish law, an Irish incorporated company that satisfies certain conditions is treated as non-Irish resident if it is managed and controlled in another jurisdiction.

Proposed change

Finance Bill 2014 (the Bill) replaces the existing corporate residence rules. Under the new provisions:

the general rule will be that an Irish incorporated company will be treated as Irish tax resident; and

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