Ireland

Research notes

Ireland — family-office tax dossier

Last reviewed: 2026-10-16 Tax year: 2026 Reviewer: research agent (Claude), unreviewed by a tax adviser

Summary

Ireland taxes a resident's capital gains at 31% for disposals on or after 7 October 2026 (33% before; EUR 1,270 annual exemption) and dividends as ordinary income at up to about 55% (40% income tax, 11% USC on non-PAYE income above EUR 100,000, and PRSI of 4.35% on unearned income). There is no wealth tax. Gifts and inheritances are taxed by Capital Acquisitions Tax at 33% above a lifetime threshold per child of EUR 420,000 (Group A, from 7 October 2026; EUR 400,000 before). Residents who are not Irish-domiciled can use the remittance basis: foreign income and foreign gains are taxed only when brought into Ireland, and foreign assets of a non-domiciled donor stay outside CAT until five consecutive years of Irish residence. An Irish investment company pays 12.5% on qualifying foreign portfolio dividends and 33% on gains, but extracting money bears about 55% personal tax.

Residence and eligibility

Resident if present 183 days in a tax year, or 280 days over the tax year and the previous year (at least 30 days in each); any part of a day counts. Ordinary residence starts after three consecutive years of residence and continues for three years after leaving. Domicile is separate (permanent home), and governs access to the remittance basis.

• EU/EEA/Swiss free movement (and UK under the Common Travel Area) (EU): No permit needed.
• Stamp 0 permission for persons of independent means (US, OTHER): Permission to reside without working for people with sufficient independent income and private health insurance. The Immigrant Investor Programme closed to new applications in 2023. Thresholds not verified in this session.

Standard regime eligibility: Tax residence: 183 days in the tax year, or 280 days over the tax year and the previous year (with at least 30 days in each). This regime applies in full to Irish-domiciled residents; a new arrival usually keeps a foreign domicile and can choose the remittance basis instead.

Capital gains

Capital gains are taxed at 31% for disposals made on or after 7 October 2026 (Budget 2027; 33% before that date, and 33% still for development land), with an annual exemption of EUR 1,270 per person (not transferable between spouses). The main residence is exempt. Gains on certain fund interests and life policies are taxed separately (PwC cites 40%; Budget 2027 reduces the fund and life-assurance rate from 38% to 35% from 1 January 2027 per KPMG). A reduced 10% rate (revised entrepreneur relief) applies to qualifying business disposals up to a lifetime limit of EUR 1.5 million.

JSON values: headline rate 31% (0.31); listed securities domestic 31% (0.31), foreign 31% (0.31); private business sale 31% (0.31); local real estate 31% (0.31); foreign real estate 31% (0.31).

• How the JSON numbers were derived: Standard CGT rate 31% for all assets for disposals on or after 7 October 2026 (Revenue eBrief 142/26); no USC or PRSI on capital gains. Private business sale shown at 31% because revised entrepreneur relief (10%) is capped and conditional on working in the business.
• Holding periods: None; no indexation for assets acquired after 2002.
• Professional-trader risk: Frequent trading can be treated as a trade (Schedule D Case I), taxing profits as income at up to about 55% including USC and PRSI.
• Foreign assets: Domiciled residents: worldwide gains taxed as they arise. Non-domiciled residents: see the remittance basis regime.
• Exemptions and thresholds: Annual exemption EUR 1,270 per individual. Principal private residence relief.
• Eligibility conditions: Resident or ordinarily resident individual.
• Regional differences: None.
• Important exceptions / announced changes: Irish and EU-domiciled ETFs/funds: gains and distributions are subject to a separate 'exit tax' regime with an 8-year deemed disposal (rate cited by PwC as 40% for certain fund interests; Finance Act 2025 changes not verified). Ireland has no general exit tax on individuals leaving (not verified in statute).
• Tax year / confidence / verification: 2026 / medium / partially_verified (checked 2026-10-16)
• Sources: Ireland - Individual - Income determination; Ireland - Individual - Residence; Revenue eBrief No. 142/26; Budget 2027: tax rates and credits

Dividends

Dividends, Irish or foreign, are taxed as income at the marginal rate of 40%, plus USC of 8% (11% on non-PAYE income above EUR 100,000, i.e. an 8% rate plus a 3% surcharge), plus PRSI on unearned income (4.35% from 1 October 2026): about 55.35% at the top. Irish companies withhold 25% dividend withholding tax, which is credited. Foreign withholding tax is credited under the treaties, up to the Irish tax on the same income.

JSON values: headline 55.35% (0.5535); domestic 55.35% (0.5535); foreign gross 55.35% (0.5535); foreign tax relief: credit.

• How the JSON numbers were derived: 40% income tax (above EUR 44,000 single / 53,000-88,000 married) + 11% USC (8% rate, plus the 3% surcharge on non-PAYE income above EUR 100,000) + 4.35% PRSI (unearned income, from 1 October 2026) = 55.35%. The 3% surcharge applies to income above EUR 100,000 only; the model uses the top marginal rate throughout, as the family's dividends are about EUR 600,000.
• Outbound withholding: 25% dividend withholding tax on dividends paid by Irish companies; exemptions for non-resident individuals in treaty/EU states and companies with documentation.
• Treaty network: About 75 income tax treaties, including the US and all EU states (count from general knowledge).
• Holding-company notes: Modelled as the investment_company structure regime: an Irish close company pays 12.5% on foreign portfolio dividends from EU or treaty-country listed companies (portfolio investor rule, s.21B TCA 1997), nothing on Irish dividends (franked investment income), and 33% on gains; extracting money then bears income tax, USC and PRSI of about 55.35% on the dividend. The 20% close-company surcharge (s.440) falls on income that is not distributed.
• Exemptions and thresholds: No dividend allowance.
• Eligibility conditions: Resident individual.
• Regional differences: None.
• Important exceptions / announced changes: PRSI on unearned income rises in annual steps each October (4.2% to 4.35% on 1 October 2026 per the tax-firm summaries; the Class K rate itself was not read on an official page). USC and the Class K rate for the year are blended across the 2026 tax year in practice; the 2026 steady-state top rate is used.
• Tax year / confidence / verification: 2026 / medium / partially_verified (checked 2026-10-16)
• Sources: Budget 2027: tax rates and credits; Universal Social Charge and PRSI; Dividend income; Ireland - Individual - Taxes on personal income; USC standard rates and thresholds; Other rates of USC (3% surcharge); Ireland - Individual - Income determination

Inheritance and gifts to children

Capital Acquisitions Tax (CAT) is charged on the recipient at 33% on gifts and inheritances above a lifetime tax-free threshold per group. A child (Group A) can receive EUR 420,000 in total from both parents combined (all Group A benefits since 5 December 1991 are aggregated) for gifts or inheritances on or after 7 October 2026; the threshold was EUR 400,000 from 2 October 2024 to 6 October 2026. Spouses are exempt. Each person can give EUR 3,000 a year to anyone tax-free.

JSON values: basis beneficiary, bracket mode marginal, children taxed, exemption EUR 420,000, marginal brackets above the exemption: 33% (0.33) from EUR 0; other transfer costs 0% (0); gifts same as inheritance: True; tax-free after years: None.

• Gifts: Gifts are taxed the same way as inheritances (33% above the shared Group A threshold, aggregated for life since 5 December 1991), plus a EUR 3,000 annual small gift exemption per donor. A gift of assets standing at a gain can also trigger CGT for the donor, creditable against the CAT on the same event.
• Business relief: Business relief reduces the taxable value of relevant business property by 90% under conditions; it does not extend to businesses that consist wholly or mainly of making or holding investments (Revenue CAT manual Part 12, s.93 CATCA 2003), so neither a portfolio of listed shares nor the shares of a company holding one qualify. Covers listed portfolios: no.
• Foreign assets: Worldwide assets in scope if disponer or beneficiary is resident or ordinarily resident (subject to the five-year rule for non-domiciled persons). Foreign inheritance tax can be credited.
• Domicile / residence rules: Scope follows residence or ordinary residence of either party; a person stays ordinarily resident for three years after leaving. Non-domiciled persons are treated as in scope only after five consecutive years of residence.
• Exemptions and thresholds: Group A threshold EUR 420,000 (from 7 October 2026), a lifetime amount covering all gifts and inheritances from parents. Small gift exemption EUR 3,000 per donor per recipient per calendar year. Spouse/civil partner exempt. Dwelling house exemption for a child who lived in the home (conditions not verified).
• Eligibility conditions: In scope if the disponer or the beneficiary is resident or ordinarily resident in Ireland, or the property is Irish-situated.
• Regional differences: None.
• Important exceptions / announced changes: A foreign-domiciled disponer or beneficiary counts as resident/ordinarily resident for CAT only after five consecutive tax years of Irish residence (and still resident at the date of the gift or inheritance); until then foreign assets passing between non-domiciled persons are outside CAT (rule from general knowledge, s. 6 CATCA 2003; statute page blocked).
• Tax year / confidence / verification: 2026 / high / partially_verified (checked 2026-10-15)
• Sources: CAT group thresholds; CAT thresholds, rates and aggregation rules; Gift and Inheritance Tax (CAT); What do you not pay CAT on?; CAT rates; Tax and Duty Manual CAT Part 12: Business relief; Ireland - Individual - Other taxes
• Surviving spouse and civil partner: inheritance is fully exempt from CAT (CATCA 2003 s.71) and does not use the Group A threshold.

Wealth tax

Ireland has no net wealth tax on individuals.

JSON type: none.

• Property tax (not a wealth tax): Local Property Tax on Irish residential property, banded by value (generally a fraction of a percent a year).
• Important exceptions / announced changes: Domicile levy (Part 18C TCA 1997): EUR 200,000 a year for an individual who in the tax year is Irish-domiciled, has world-wide income above EUR 1 million, an Irish income tax liability below EUR 200,000, and Irish property worth more than EUR 5 million on 31 December. Residence is irrelevant and there is no citizenship test; Irish income tax paid is credited against it. 'Irish property' excludes shares in trading companies and trading holding companies. A non-domiciled arrival is outside it; a family that later acquires an Irish domicile of choice would normally pay more than EUR 200,000 of Irish income tax on a large income and so owe little or nothing. Not modelled as a wealth tax.
• Tax year / confidence / verification: 2026 / high / verified (checked 2026-10-15)
• Sources: Ireland - Individual - Other taxes

Special regimes

Remittance basis for residents not domiciled in Ireland (remittance_basis)

A resident who is not Irish-domiciled pays income tax on foreign investment income and CGT on foreign gains only to the extent they are remitted (brought) to Ireland. Irish-source income, Irish dividends and gains on Irish assets stay fully taxable. Inheritance tax follows the standard rules, but foreign assets of a non-domiciled family stay outside CAT for the first five consecutive years of residence.

• Eligible citizenships: EU, US, OTHER
• Eligibility: Irish tax resident but domiciled outside Ireland (domicile of origin abroad, no intention to stay permanently). No minimum stay, fee or application; claimed in the tax return. Must fund Irish living costs from Irish income, unremitted capital or clean capital without bringing in untaxed foreign income or gains.
• Duration: indefinite years
• Duration note: No statutory time limit: the remittance basis applies for as long as the person is Irish-resident but not Irish-domiciled. It ends if the person acquires an Irish domicile of choice (settling permanently), which becomes more likely the longer the family stays. The CAT advantage for foreign assets lasts only until five consecutive years of residence.

Capital gains under this regime

Foreign gains are taxed at 31% (disposals on or after 7 October 2026; 33% before) only when the proceeds are remitted to Ireland; unremitted foreign gains are not taxed. Gains on Irish assets (including Irish-listed shares and Irish real estate) are taxed at 31% as they arise.

JSON values: headline rate 31% (0.31); listed securities domestic 31% (0.31), foreign 0% (0.0); private business sale 0% (0.0); local real estate 31% (0.31); foreign real estate 0% (0.0).

• How the JSON numbers were derived: 0 for foreign listed securities, foreign private companies and foreign real estate on the assumption that proceeds stay outside Ireland; 31% on Irish assets and on anything remitted.
• Holding periods: None.
• Professional-trader risk: As standard.
• Foreign assets: Taxed only on remittance.
• Exemptions and thresholds: EUR 1,270 annual exemption on taxable gains; losses on foreign assets are not deductible for a remittance-basis taxpayer.
• Eligibility conditions: Not Irish-domiciled. The 0% rates for foreign listed securities, foreign private companies and foreign real estate assume the gains (and the sale proceeds containing them) are never remitted to Ireland, directly or indirectly; a remitted foreign gain is taxed at 31% in the year it is brought in. Gains on Irish assets are taxed as they arise.
• Important exceptions / announced changes: Domicile can be lost over a long stay (acquiring an Irish domicile of choice) which ends the regime. Remitting the proceeds of a sale also remits the gain.
• Tax year / confidence / verification: 2026 / medium / partially_verified (checked 2026-10-16)
• Sources: Ireland - Individual - Income determination; Revenue eBrief No. 142/26; Tax and Duty Manual Part 05-01-21: Remittance basis

Dividends under this regime

Foreign dividends are taxed only when remitted to Ireland, then at up to about 55.35%. Irish dividends are taxed as they arise.

JSON values: headline 55.35% (0.5535); domestic 55.35% (0.5535); foreign gross 0% (0.0); foreign tax relief: not_applicable.

• How the JSON numbers were derived: Foreign dividends kept abroad: 0 (taxed at ~55.35% if remitted). Irish dividends as standard.
• Outbound withholding: As standard (25%).
• Treaty network: As standard; foreign withholding tax is a final cost on unremitted dividends.
• Exemptions and thresholds: None.
• Eligibility conditions: Not Irish-domiciled. The 0% foreign dividend rate assumes the dividends are kept outside Ireland and never remitted; remitted foreign dividends are taxed at the marginal income tax rate plus USC and PRSI (about 55.35% at the top). Irish dividends are taxed as they arise.
• Tax year / confidence / verification: 2026 / medium / partially_verified (checked 2026-10-16)
• Sources: Ireland - Individual - Taxes on personal income; Tax and Duty Manual Part 05-01-21: Remittance basis

Metrics not listed inherit the standard regime.

Holding structures

Modelled: Irish private investment company (close company), regime `investment_company`, type `structure`. The family holds the portfolio through an Irish private company limited by shares that they own.

• Dividends in the company: dividends from Irish companies are franked investment income and bear nothing (JSON domestic 0). Dividends from companies resident in an EU member state or a treaty country bear 12.5% when the company holds no more than 5% (portfolio investor rule, s.21B TCA 1997); other foreign dividends bear 25%. JSON: foreign gross rate 0.125 with foreign tax credit credit, credited only up to the Irish tax on the same dividend, so a 15% withholding exceeds the 12.5% and the excess is lost.
• Gains in the company: corporation tax on chargeable gains at an effective 33% (PwC); there is no participation exemption for portfolio holdings (s.626B needs at least 5% in a qualifying subsidiary). The JSON records 0.31 for listed securities and 0.31 as headline, on the assumption that the 31% personal CGT rate from 7 October 2026 reaches companies through TCA 1997 s.78, while its own rate basis and summary still cite 33%; local real estate 0.33; private business sale and foreign real estate null (not researched).
• Payout: a dividend to a resident parent is taxed at 40% income tax, USC 11% on non-PAYE income above EUR 100,000 and PRSI 4.35%, on the gross dividend; the company's 25% dividend withholding tax is credited. payout_tax_rate 0.5535, the top marginal rate on all of it; each parent has own bands, so a EUR 400,000 payout split between two parents would bear somewhat less.
• Close-company surcharge (s.440 TCA 1997): 20% on the excess of the company's distributable estate and investment income (after corporation tax) over the dividends declared for the period and paid within 18 months; none if the excess is EUR 2,000 or less. A family that pays out at least the year's investment income each year owes no surcharge. Chargeable gains are not part of the income definition quoted in Revenue's manual.
• Wealth tax and inheritance: no wealth tax on the company or its shares. The shares are in the parents' estate at market value for CAT with no business relief, because business relief excludes companies whose business is holding investments (Revenue CAT manual Part 12).
• Getting assets in: putting an existing personal portfolio into the company is a disposal at market value for the individual, taxed at CGT (31%) on any latent gain. US citizens are excluded (CFC and PFIC rules).
• Exit and liquidation: liquidation proceeds above the paid-in capital are a capital distribution (not verified). Running and set-up costs are null in the JSON (not researched).

Company taxation (kept separate from personal tax)

Headline CIT rate in JSON: 12.5% (0.125).

12.5% on trading profits; 25% on passive (non-trading) income such as interest, rent and certain foreign dividends; 33% on chargeable gains. Pillar Two 15% minimum for groups with revenue of EUR 750 million or more. Close companies face a surcharge on undistributed investment income.

Special zones: None.

Cost of living notes

Dublin (prime south Dublin and coastal suburbs).

• Prime family rent: EUR 6,198/month, the median of 18 distinct 4-6 bedroom houses listed for rent on MyHome.ie on 15 October 2026 in Dublin 4/6/14/18, Blackrock, Booterstown, Monkstown, Dún Laoghaire, Dalkey and Malahide (range EUR 3,500-15,950; Ballsbridge/Sandymount houses EUR 10,500-13,000). Asking rents.
• International school: Nord Anglia International School Dublin, Grades 11-12, EUR 25,296 a year for 2026-2027 (Grades 9-10 EUR 23,971); one-time enrolment fee EUR 1,600.
• Not sourced: price per m², family health insurance, housekeeper.

Open questions

• Special Assignee Relief Programme (SARP; renewed to 2030 with a EUR 125,000 minimum income) relieves employment income only and is not modelled.
• The Class K PRSI rate from 1 October 2026 (4.35%) was not read on an official page.
• Budget 2027 (announced October 2026) measures beyond the CAT threshold were not checked.
• (standard / capital_gains) Revised entrepreneur relief (10% up to a lifetime limit, EUR 1m historically; Budget changes not checked) was not verified in this session.
• (standard / capital_gains) The current exit-tax/deemed-disposal rate for funds and ETFs after Finance Act 2025 was not verified; PwC still cites 40% for certain fund interests.
• (standard / capital_gains) The 31% rate rests on Revenue eBrief 142/26 (manual updated) and tax-firm summaries of Budget 2027; the Finance Act text enacting it was not read.
• (standard / capital_gains) Revenue's CGT rate page returned 404 (the 33% to 31% change is therefore sourced from the eBrief).
• (standard / dividends) PRSI Class K rate on unearned income from 1 October 2026 (4.35%) is taken from tax-firm summaries of the self-employed/Class A schedule; the official gov.ie Class K page returned 403.
• (standard / dividends) Whether the 3% USC surcharge applies only to the part of non-PAYE income above EUR 100,000 (KPMG and the Law Society show 11% above EUR 100,000) is read from those summaries; the Revenue page does not say.
• (standard / inheritance) The EUR 420,000 threshold from 7 October 2026 is shown on Revenue's site; confirm it is enacted in the Finance Act following Budget 2027.
• (standard / inheritance) Agricultural relief and the dwelling-house exemption were not verified on official pages.
• (standard / inheritance) The five-year rule for foreign-domiciled persons (s. 6 CATCA 2003) could not be opened on irishstatutebook.ie (403).
• (investment_company / capital_gains) Whether the Finance Act that enacts the 31% personal CGT rate also changes the 33% effective rate on company gains was not checked; company gains follow the CGT rate through TCA 1997 s.78, and the 31% from 7 October 2026 is assumed to reach companies too, but the s.78 fraction after Finance Act 2026 was not read. Private business sale and foreign real estate left null: not researched for a company.
• (investment_company / dividends) Revenue's manual does not address a pure investment company claiming the portfolio-investor route; if Revenue refused it, foreign dividends would bear 25%. The credit mechanism for foreign withholding (Schedule 24 TCA 1997, limited to the Irish tax on the income) was not read.
• (remittance_basis / capital_gains) Only PwC was opened; Revenue's guidance on remittance basis and loss treatment was not read.

US citizens: US-Ireland income tax treaty applies; there is no estate tax treaty. The remittance basis does not help US citizens with US tax. Irish CAT at 33% can be credited against US estate tax only within US foreign death tax credit rules. Irish/EU ETFs are PFICs for US persons.

Sources

• Ireland - Individual - Income determination — PwC Worldwide Tax Summaries (professional)
• Ireland - Individual - Residence — PwC Worldwide Tax Summaries (professional)
• Ireland - Individual - Taxes on personal income — PwC Worldwide Tax Summaries (professional)
• USC standard rates and thresholds — Revenue Commissioners (tax_authority)
• Other rates of USC (3% surcharge) — Revenue Commissioners (tax_authority)
• Ireland - Individual - Other taxes — PwC Worldwide Tax Summaries (professional)
• CAT group thresholds — Revenue Commissioners (tax_authority)
• CAT thresholds, rates and aggregation rules — Revenue Commissioners (tax_authority)
• Gift and Inheritance Tax (CAT) — Revenue Commissioners (tax_authority)
• What do you not pay CAT on? — Revenue Commissioners (tax_authority)
• Ireland - Corporate - Taxes on corporate income — PwC Worldwide Tax Summaries (professional)
• MyHome.ie: properties with 4+ bedrooms to rent in Dublin (listing sample) — MyHome.ie (other)
• Nord Anglia International School Dublin: 2026-2027 Tuition Fees — Nord Anglia International School Dublin (other)
• Tax and Duty Manual Part 18C-00-01: Domicile Levy (last reviewed August 2026) — Revenue Commissioners (Ireland) (tax_authority)
• Tax and Duty Manual Part 13-02-05: Surcharge on certain undistributed income of close companies — Revenue
• Ireland - Corporate - Income determination — PwC
• Revenue eBrief No. 142/26 (Budget 2027: CGT rate reduced to 31% for disposals on or after 7 October 2026) — Revenue Commissioners (tax_authority)
• Budget 2027: tax rates and credits — KPMG Ireland (professional)
• Universal Social Charge and PRSI — Law Society of Ireland (professional)
• Dividend income — Revenue Commissioners (tax_authority)
• CAT rates — Revenue Commissioners (tax_authority)
• Tax and Duty Manual CAT Part 12: Business relief (section 90-101 CATCA 2003) — Revenue Commissioners (tax_authority)
• Tax and Duty Manual Part 05-01-21: Remittance basis — Revenue Commissioners (tax_authority)
• Tax and Duty Manual Part 02-02-03a: Tax treatment of certain dividends (section 21B TCA 1997) — Revenue Commissioners (tax_authority)
• Capital Acquisitions Tax Consolidation Act 2003, section 71 (exemption for spouses, inheritances): https://www.irishstatutebook.ie/eli/2003/act/1/section/71/enacted/en/html

Change log

• 2026-10-15: initial research.
• 2026-10-15: added prime rent (MyHome.ie sample, EUR 6,198/month) and NAIS Dublin fee (EUR 25,296, 2026-27); remittance-basis eligibility conditions now state that the 0% rates assume no remittance; domicile levy conditions re-checked against Revenue's Tax and Duty Manual Part 18C (August 2026).
• 2026-10-15: holding-structure review: no structure added (33% gains, 25% passive income, 20% close-company surcharge, ~55% payout); holding_company_notes updated.
• 2026-10-15: family rent re-checked against the upper-middle-class standard: kept.
• 2026-10-16: added surviving-spouse treatment.
• 2026-10-16: CGT rate cut to 31% for disposals on or after 7 October 2026 (Revenue eBrief 142/26); dividend top rate 55.35% (USC 11% above EUR 100,000, PRSI 4.35%); business relief shown as excluding investment companies; added the investment_company structure regime and rewrote the Holding structures section.