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Taxation of Foreign Pensions in Ireland – Walking the Tricky Tightrope

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Taxation of Foreign Pensions in Ireland – Walking the Tricky Tightrope

As more individuals relocate to Ireland, the taxation of assets brought with them takes on importance once Irish tax residence is established. Of special concern are pension products that individuals accumulate while living and working outside of Ireland. The taxation of lump sum payments from foreign pensions is a complex affair. Under Irish law, most foreign pensions schemes are considered nonqualifying overseas pension plans. Consequently, lump sum payments from such pension plans should not be taxable in Ireland because no domestic legislation exists to tax lump sums. Lisa Cantillon, a Director in the Dublin office of KTA, explains all, but cautions that the Irish Revenue have a different view, notwithstanding the absence of statutory support.

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D.A.C.6 in Ireland – Key Features of the Administrative Guidance

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D.A.C.6 in Ireland – Key Features of the Administrative Guidance

In his article entitled “D.A.C.6 in Ireland – Key Features of the Administrative Guidance,” Martin Phelan of Simmons & Simmons, Dublin, addresses the rules that apply to “cross-border arrangements” that will be reportable if one or more relevant “Hallmarks” are applicable. His F.A.Q.’s allow the reader to focus easily on the most important issues and answers.

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Insights Vol. 4 No. 5: Updates & Other Tidbits

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Insights Vol. 4 No. 5: Updates & Other Tidbits

This month, Astrid Champion and Nina Krauthamer look briefly at several timely issues, including (i) a novel claim of treaty residence in Ireland by a nonresident Irish domiciled individual subject to the domicile levy under Irish law and (ii) the introduction of a beneficial ownership register regime in the Cayman Islands regarding certain Cayman Islands corporations.

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Insights Vol. 3 No. 8: Updates & Other Tidbits

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Fanny Karaman, Galia Antebi, and Nina Krauthamer address recent developments involving (i) the U.S. Treasury Department’s Priority Guidance Plan in the international arena, (ii) the negotiation of a new income tax treaty between the U.S. and Ireland, and (iii) a recently discovered abuse when a disregarded L.L.C. owned by a single foreign member sells U.S. real estate.

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Non-Dom Taxation: Ireland as an Alternative to the U.K.

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The benefits and possible pitfall of Ireland’s non-domiciled taxation rules are explained by Lisa Cantillon and Jane Florides of Kennelly Tax Advisers in Dublin. Remittance based taxation remains strong in Ireland, but planning is required to steer clear of deemed remittance traps and to minimize inheritance tax exposure.

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The Future of Ireland as a Place to Carry On Business in Light of Recent E.U. & O.E.C.D. Initiatives

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INTRODUCTION

Ireland has long been established as the onshore location of choice for the world’s leading multinational enterprises (“M.N.E.’s”). Although Ireland’s attractiveness as a location for foreign direct investment is based on a number of factors, the low corporate tax rate of 12.5% is crucial.

Ireland’s corporate tax regime has received persistent and pervasive scrutiny from international media in recent times, focusing on topics such as the “Double Irish,” the O.E.C.D. B.E.P.S. initiative, and the Apple investigation. What must not be forgotten in the midst of such coverage is that Ireland has nothing to hide and nothing to fear from any of the above issues. Ireland is a small jurisdiction, and as far back as the 1950’s, the cornerstone of the economy has been foreign direct investment (“F.D.I.”).

Ireland makes no secret of its wish to compete with other jurisdictions for F.D.I., and its highly competitive corporate tax regime, including the 12.5% tax rate, forms part of a broader strategy that allows Ireland to “play to win.”

This article will discuss some of the main O.E.C.D. and E.U. initiatives impacting Ireland and the effects such initiatives are likely to have on Ireland and the M.N.E.’s which are based here.