General Rule For all tax purposes, the United Kingdom includes the six counties of Northern Ireland as well as Scotland, England and Wales. An individual or company which is neither resident nor ordinarily resident in the UK will generally be liable to UK income tax on UK source income only. This would include UK rents, […]
Branch or Subsidiary There is generally no UK tax on profits earned in the UK by an Irish resident individual or company, unless they are earned by a UK branch or UK resident subsidiary. Therefore it is possible to do a very considerable degree of business in UK without coming within the remit of UK […]
Overview There is legislation in the UK, of which there is no equivalent in Ireland, designed to prevent UK companies diverting profits out of the UK to countries charging low rates of Corporation Tax. These companies are called “controlled foreign companies”. A “controlled foreign company” is one resident outside the UK and controlled by persons […]
This note looks at overseas tax issues from the UK perspective. This position is broadly similar to the equivalent Irish position. A company resident in the UK is subject to Corporation Tax on its worldwide income. An overseas branch is an extension of the UK business. A branch is the company’s presence in another jurisdiction. […]
Trading from Ireland Provided an individual trader or the partners of a partnership are resident in Ireland and not resident or ordinarily resident in the UK, then no UK Income Tax can arise on the business profits, unless there is a branch or permanent establishment in the UK through which the business is carried […]
Double Taxation Treaties The OECD is an organisation of developed countries whose purpose is to expand world trade and maintain stability. The OECD has published a model double taxation convention which forms the basis for most double taxation agreements between “Western” countries. The main function of double taxation treaties is to avoid double tax on […]
Dividends from UK Companies Where an Irish resident Individual or an Irish resident Company receives dividend income from a UK company, Irish Taxation implications arise. In the case of an individual the income received is part of the individual’s total income subject to income tax at the current highest rate of 41%. Credit is available […]
Residence The receipt of income by an Irish resident individual from a source in the UK will have implications under both Irish and UK tax law. The source could, for example, be rent from a UK property, dividends form a UK company, UK savings income, UK employment income etc. Under Irish Tax Law, a person […]
A company resident in the UK is subject to Corporation Tax on its worldwide income. An overseas branch is an extension of the UK business. A branch is where a company has a presence in another jurisdiction. There must be some minimal element of an establishment to the other jurisdiction in order to constitute a […]