Tax Residence

A company or other corporate is deemed resident in Ireland if it is managed and controlled in Ireland. An Irish incorporated company is deemed Irish tax resident in all cases. The only exception is where it is deemed tax resident in another country for the purposes of a double taxation agreement.

Where a company or a related company undertakes a trade in Ireland and is either  controlled by persons resident in the EU or another country with which Ireland has a double taxation treaty or the company or related companies are quoted on a recognised stock exchange, then an Irish incorporated company was formerly subject to the central management and control test only.

The exception does not apply from 1 January 2015 (or from 23 October 2013 for companies incorporated on or after that date) if the Irish incorporated company was tax resident nowhere. In this case, it is deemed resident in Ireland

In the case of companies incorporated before 1 January 2015 provisions apply from 1 January 2021 or when after 1 January 2015 there is a change of ownership in the company in circumstances where there is also a major change in the conduct and nature of the business of the company within a period of one year before the change of ownership (of 1 January 2015 if after that and ending five years thereafter.