---
title: "Ireland kept the non-dom regime the UK abolished"
url: https://www.boruconsulting.com/blog/ireland-non-dom-tax-regime
category: "Taxation Strategy"
author: "Ruairi Laughlin-McCann"
published: 2026-11-11
modified: 2026-11-11
---

# Ireland kept the non-dom regime the UK abolished

> Ireland still taxes a resident who is not Irish domiciled on foreign income and gains only when they are brought into Ireland, with no annual charge and no time limit. For a UK leaver it is narrower than it looks: Irish work is taxed in full, gifts come into Irish tax after five years, and UK tax follows.

## Key Takeaways
- Ireland has kept the remittance basis that the UK abolished from 6 April 2025. An individual who is Irish tax resident but not domiciled in Ireland pays Irish tax on Irish income and gains in full, and on foreign income and gains only to the extent that they are remitted into Ireland, with no annual charge and no fixed time limit.
- The regime protects investment wealth, not earned income. Income from employment duties performed in Ireland is taxed in Ireland in full wherever the employer and the bank account are, and Irish property and Irish-source income are taxed in full at Irish rates, including capital gains at 31% for disposals from 7 October 2026.
- Irish gift and inheritance tax arrives later but arrives. A non-domiciled individual comes within Capital Acquisitions Tax on foreign assets after five consecutive tax years of Irish residence, at 33% above group thresholds that rose to €420,000 for children from 7 October 2026, while Irish-situated property is within the tax from the start.
- Leaving the UK does not end UK tax. A long-term UK resident stays within UK inheritance tax for three to ten tax years after departure, gains realised during a stay abroad of five years or less can be taxed on return, and pre-departure foreign income remitted to the UK in that period is taxed in the year of return.
- Residence in Ireland is a day count, domicile is a fact. Irish tax residence follows 183 days in a tax year or 280 days over two years, and non-domiciled status depends on keeping a genuine intention to return to the country of origin, which Revenue can test.

## The regime the UK closed is still open next door

From 6 April 2025 the United Kingdom abolished the remittance basis and replaced domicile with residence as the test for both income tax and inheritance tax. A non-domiciled individual living in the UK is now taxed on worldwide income and gains after a four-year window for new arrivals, and becomes exposed to inheritance tax on a worldwide estate after ten years of residence.

Ireland did not follow. It still distinguishes residence from domicile, and it still taxes a resident who is not Irish domiciled on foreign income and gains only when they are brought into the country. It charges nothing for the privilege, unlike the annual charge the UK levied on long-staying remittance basis users, and it sets no fixed limit on how long the status lasts.

For a family that built its affairs around the UK regime, the Irish rules read like an inheritance. They are not quite that. The Irish remittance basis is a regime for investment wealth held abroad. It does not shelter Irish work, Irish property or Irish gifts after five years, and it does nothing about the UK tax that follows anyone who leaves the UK after a long stay. The question worth answering is not whether Ireland has a non-dom regime. It is what a particular family would actually keep outside tax, on both sides of the Irish Sea, once every rule is applied.

## How the Irish remittance basis works

Irish tax depends on three separate statuses: residence, ordinary residence and domicile. The remittance basis turns on the third.

**Residence is a day count.** An individual is Irish tax resident for a tax year, which in Ireland is the calendar year, if present for 183 days or more in that year, or for 280 days or more across that year and the previous one, with any year of 30 days or fewer ignored for the two-year test. The tests are set out by [Citizens Information](https://www.citizensinformation.ie/en/money-and-tax/tax/moving-country-and-taxation/tax-residence-and-domicile-in-ireland/), and an individual arriving part-way through a year who intends to be resident the following year can elect to be resident in the year of arrival.

**Ordinary residence follows three years.** An individual who has been Irish resident for three consecutive tax years becomes [ordinarily resident](https://www.revenue.ie/en/jobs-and-pensions/tax-residence/ordinarily-resident-tax-purposes.aspx) from the fourth, and remains ordinarily resident for three tax years after leaving.

**Domicile is a fact about intention.** Revenue describes [domicile](https://www.revenue.ie/en/jobs-and-pensions/tax-residence/domicile-domicile-levy.aspx) as living in a country with the intention of living there permanently. Everyone has a domicile of origin at birth. Acquiring a new one requires clear evidence of an intention to live permanently in the new country and not to return to the domicile of origin. A British or other foreign national who moves to Ireland keeps a foreign domicile of origin unless that evidence exists.

**The remittance basis.** Under section 71 of the Taxes Consolidation Act 1997 (TCA 1997) for income, and section 29 of the same Act for gains, an individual who is resident but not domiciled in Ireland is taxed on Irish income and gains as they arise, and on foreign income and gains only to the extent that they are remitted into Ireland. Revenue's guidance on [foreign rental income](https://www.revenue.ie/en/property/rental-income/foreign-rental-income/index.aspx) states the rule in one line: a non-domiciled resident pays Irish tax only on the foreign rent brought into Ireland.

**What is not taxed when it arrives.** Professional commentary, including the Irish practices of the large firms, treats money that was already capital before the individual became Irish resident, such as savings and the proceeds of assets sold before arrival, as capital that can be brought into Ireland without an Irish charge. Revenue's own manual on the remittance basis addresses the same question, on income accumulated before residence and remitted afterwards. This is the main reason the timing of arrival matters: what is sold, realised and banked before Irish residence starts is the cleanest money a family will have.

**There is no charge and no clock.** Ireland levies no annual payment for the remittance basis and has no equivalent of the UK's former deemed domicile after 15 years for income tax and capital gains tax. The status lasts as long as the domicile of origin is retained.

The domicile levy is not part of this regime. It is an annual €200,000 levy on Irish-domiciled individuals with worldwide income above €1 million, Irish property worth more than €5 million and an Irish income tax bill below €200,000 for the year. It does not apply to someone who is not Irish domiciled.

## What the remittance basis does not cover

The Irish regime is narrower than the UK regime it is often compared with, and the gaps fall exactly where a UK leaver's income tends to be.

**Work performed in Ireland.** Income from an employment whose duties are carried out in Ireland is taxable in Ireland whether the employer is Irish or foreign and wherever the salary is paid. Revenue's [residence overview](https://www.revenue.ie/en/jobs-and-pensions/tax-residence/index.aspx) states the rule even for non-residents. A UK executive who relocates to Dublin and keeps a UK employment contract does not keep the salary outside Irish tax by leaving it in a London account. Inbound employees are dealt with instead by the Special Assignee Relief Programme, set out in the note on [SARP after 2026](https://www.boruconsulting.com/blog/sarp-ireland-125k-threshold-2026).

**Irish income and Irish assets.** Irish rent, Irish dividends and Irish interest are taxed as they arise. Gains on Irish assets are taxed in full, at a standard capital gains tax rate of 31% for disposals on or after 7 October 2026, down from 33%, as set out in the note on [the Irish investment account and the 2027 rate cuts](https://www.boruconsulting.com/blog/ireland-investment-account-1-percent-tax).

**UK-source income and gains.** The treatment of UK income has its own history in the Irish rules. Revenue's manual on the [remittance basis of assessment](https://www.revenue.ie/en/tax-professionals/tdm/income-tax-capital-gains-tax-corporation-tax/part-05/05-01-21a.pdf) carries a separate section on Finance Act 2008 and UK-source income, and another on issues with UK-source income and gains. For a UK leaver, whose portfolio, pension and property are often still in the UK, that is the first part of the Irish rules to read, and the [UK–Ireland double taxation convention](https://www.gov.uk/government/publications/ireland-tax-treaties/1976-uk-ireland-double-taxation-convention-as-amended-by-the-1998-protocol-in-force) is the second.

**Money routed through a spouse.** Since Finance Act 2013, foreign income transferred or lent to a spouse or civil partner and then brought into Ireland can be treated as remitted by the individual who earned it. The route that worked for a generation of UK non-doms has no Irish equivalent.

**Offshore funds.** Ireland applies its own regime to certain offshore funds, and commentary notes that income and gains within it may not benefit from the remittance basis. A portfolio of non-Irish funds needs to be reviewed fund by fund before arrival.

The table sets out how the main kinds of income of a UK leaver are treated once Irish resident and not Irish domiciled.

| Income or gain | Irish treatment for a resident non-domiciled individual |
| --- | --- |
| Salary for duties performed in Ireland | Taxed in Ireland in full, wherever paid |
| Irish rent, dividends and interest | Taxed in Ireland as they arise |
| Gain on an Irish asset | Taxed at 31% for disposals from 7 October 2026 |
| Foreign investment income kept abroad | Not taxed in Ireland unless remitted |
| Foreign capital gain kept abroad | Not taxed in Ireland unless remitted |
| Savings that were capital before Irish residence began | Generally not taxed when brought into Ireland |
| UK-source income and gains | Check separately against the Irish rules and the UK–Ireland convention |
| Foreign income routed through a spouse into Ireland | Can be treated as remitted by the individual |

## Gift and inheritance tax arrives in year six

Ireland taxes gifts and inheritances under the Capital Acquisitions Tax Consolidation Act 2003 at [33%](https://www.revenue.ie/en/gains-gifts-and-inheritance/gift-and-inheritance-tax-cat/index.aspx) above lifetime group thresholds. Revenue confirmed in [eBrief No. 149/26](https://www.revenue.ie/en/tax-professionals/ebrief/2026/no-1492026.aspx) that increased thresholds apply to gifts and inheritances taken on or after 7 October 2026. The Group A threshold, for a child receiving from a parent, rose from €400,000 to €420,000.

Capital Acquisitions Tax looks at both sides of a transfer. A gift is within the tax if the person giving it or the person receiving it is resident or ordinarily resident in Ireland, and Irish-situated property is within it whoever is involved. For a non-domiciled individual, residence is counted differently: a foreign-domiciled person is not treated as resident for Capital Acquisitions Tax on foreign assets until five consecutive tax years of Irish residence have passed, so the exposure begins in the sixth.

The five-year rule creates the planning window that matters most for a family. A gift of foreign assets by a non-domiciled parent to a child who is not Irish resident, made within the first five years of the parent's Irish residence, can fall outside Irish Capital Acquisitions Tax. The same gift in year seven is taxed at 33% above the child's threshold. The UK side of the same gift is the subject of the next section, because the UK has its own clock running in the other direction.

## The UK tax that follows a move to Ireland

A move from the UK to Ireland is two exercises. The Irish rules decide what is taxed on arrival. The UK rules decide what is still taxed after departure, and for a long-term resident they reach further than most people leaving expect.

**Ceasing UK residence.** UK residence is decided by the statutory residence test in [Schedule 45 to the Finance Act 2013](https://www.legislation.gov.uk/ukpga/2013/29/schedule/45), with split-year treatment available in the year of departure in defined cases. The Common Travel Area means no immigration step marks the move, which makes the evidence of departure, the home, the work and the days, more important rather than less. The mechanics are in the note on [the UK statutory residence test](https://www.boruconsulting.com/blog/uk-statutory-residence-test-hnwi).

**Inheritance tax after leaving.** Since 6 April 2025, an individual who has been UK resident for 10 of the previous 20 tax years is a long-term UK resident under [section 6A of the Inheritance Tax Act 1984](https://www.legislation.gov.uk/ukpga/1984/51/section/6A) and is within UK inheritance tax on a worldwide estate. That status continues after departure for a tail of three tax years for someone resident for 10 to 13 years, rising by a year for each further year of residence to a maximum of ten. A gift made in the first five years in Ireland, outside Irish tax, can still be a transfer of value for UK inheritance tax. The detail is in the note on [the long-term resident inheritance tax tail](https://www.boruconsulting.com/blog/long-term-resident-iht-tail-planning).

**Where both countries tax the same estate.** The UK and Ireland have a double taxation convention on estates and gifts, and HMRC's manual states that relief under it [takes the form of a credit](https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm27168). HMRC sets out separately how its post-1975 conventions interact with the [long-term residence test](https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm47071), which matters for anyone who dies or gives during the tail.

**Gains realised soon after leaving.** Under the temporary non-residence rules in section 10A of the Taxation of Chargeable Gains Act 1992 and Part 4 of Schedule 45 to the Finance Act 2013, an individual who was UK resident for at least four of the seven tax years before leaving, and who returns within five years, is taxed on return on gains realised abroad on assets held before departure. A move to Ireland that turns out to be temporary can bring a large sale back into UK tax, as set out in the note on [temporary non-residence](https://www.boruconsulting.com/blog/uk-temporary-non-residence-cgt-clawback).

**Old foreign income brought to the UK.** For a former UK remittance basis user, [section 832A of the Income Tax (Trading and Other Income) Act 2005](https://www.legislation.gov.uk/ukpga/2005/5/section/832A) treats pre-departure foreign income that is remitted to the UK during a period of temporary non-residence as remitted in the year of return, and says that double taxation arrangements do not prevent the charge.

**The Temporary Repatriation Facility.** A former remittance basis user who is still UK resident can designate pre-6 April 2025 foreign income and gains at 12% in 2025/26 and 2026/27 and at 15% in 2027/28, under Schedule 10 to the Finance Act 2025. Whether that is worth paying before moving to Ireland depends on where the money is going. Money that will be spent in Ireland is a different question from money that may one day return to the UK, and the facility is examined in the note on [the Temporary Repatriation Facility](https://www.boruconsulting.com/blog/non-dom-exit-trf-temporary-repatriation).

## The UK and Irish regimes side by side

| Point | UK until 5 April 2025 | UK from 6 April 2025 | Ireland now |
| --- | --- | --- | --- |
| Test for taxing foreign income and gains | Domicile, with a remittance basis claim | Residence; four-year exemption for new arrivals | Domicile; remittance basis for the non-domiciled |
| Annual charge | Yes, for long-staying users | Not applicable | None |
| Time limit | Deemed domicile after 15 of 20 years | Four years from arrival | No fixed limit while foreign domicile is kept |
| Employment duties in the country | Taxed in full | Taxed in full | Taxed in full |
| Gift and inheritance tax on foreign assets | After deemed domicile | After 10 of 20 years of residence | After five consecutive years of residence |
| Capital gains rate on local assets | 10% or 20%, then 18% or 24% | 18% or 24% | 31% from 7 October 2026 |

## Where the plan usually fails

The Irish regime rewards order and punishes improvisation. The failures are predictable.

**One bank account for everything.** Pre-arrival capital, income that arises after Irish residence begins, and gains realised abroad sit in one foreign account, and every transfer to Ireland draws on all three. Ireland has no statutory ordering rules of the kind the UK legislated for mixed funds, so a taxpayer cannot rely on a rule to treat the transfer as capital. Separate accounts, opened before arrival, are the only defence that works.

**Spending in Ireland with foreign money by another route.** Paying Irish expenses with a foreign card, borrowing abroad against foreign income and spending the loan in Ireland, or routing money through a spouse are all ways of bringing the money in. Commentary notes that foreign loans used for Irish spending can attract anti-avoidance rules, and the 2013 spouse rule is statutory.

**Treating a salary as foreign income.** The Irish remittance basis does not cover work done in Ireland. A move that depends on keeping earned income outside Irish tax needs a different instrument, usually SARP, and that relief has its own conditions.

**Forgetting the five years.** The window for gifts of foreign assets outside Irish Capital Acquisitions Tax closes at the end of the fifth consecutive year of residence. Families that intend to settle wealth on the next generation need to decide inside that window.

**Treating departure from the UK as an exit.** The UK inheritance tax tail, the temporary non-residence rules and section 832A all run after departure. A family that plans the Irish side alone has planned half the move.

**Weakening the domicile.** Non-domiciled status depends on the intention to return to the domicile of origin. Selling the last home there, cutting every tie and describing Ireland as home for good in documents a family later has to produce can all be evidence for Revenue that the domicile has changed.

## What to settle before moving

1. **Map the UK position first.** Count UK residence years for the inheritance tax tail, identify assets standing at a gain, and decide whether any sale belongs before departure or after five full years abroad.

2. **Separate the money before arrival.** Open distinct accounts for pre-arrival capital, post-arrival foreign income, and foreign gains, and do not mix them afterwards.

3. **Realise what can be realised in advance.** Gains and income that arise before Irish residence starts are the cleanest funds to bring into Ireland later.

4. **Read the UK-source rules for the portfolio that stays in the UK.** Pensions, UK property and UK investments each need to be checked against the Irish remittance rules and the UK–Ireland convention.

5. **Plan the earned income separately.** If either spouse will work in Ireland, test SARP and the employment position, because the remittance basis will not help.

6. **Diary the five-year Capital Acquisitions Tax window and the UK tail together.** The two clocks start at different times and run in opposite directions, and gifts need to fit both.

7. **Document the domicile.** Keep the evidence of continuing ties to the country of origin, and do not create evidence against it.

## Frequently asked questions

### Does Ireland have a non-dom tax regime?

Yes. An individual who is Irish tax resident but not domiciled in Ireland is taxed on Irish income and gains in full, and on foreign income and gains only to the extent that they are remitted into Ireland, under section 71 and section 29 of the Taxes Consolidation Act 1997. There is no annual charge and no fixed time limit while the individual keeps a foreign domicile. Employment duties performed in Ireland and Irish-source income are taxed in full.

### How does the remittance basis work in Ireland?

Foreign income and gains are taxed in Ireland only when brought into the country, whether by wire, online transfer or other means. Money that was already capital before the individual became Irish resident can generally be brought in without an Irish charge. Foreign income transferred or lent to a spouse or civil partner and then brought into Ireland can be treated as remitted by the individual, and income within Ireland's offshore funds regime may not benefit from the remittance basis.

### How many days make me tax resident in Ireland?

You are Irish tax resident for a calendar year if you spend 183 days or more in Ireland in that year, or 280 days or more across that year and the previous one, with a year of 30 days or fewer ignored for the two-year test. You become ordinarily resident after three consecutive years of residence. Residence and domicile are separate, and the remittance basis depends on domicile.

### Can a UK non-dom move to Ireland and keep the remittance basis?

A UK national who is not domiciled in Ireland can use the Irish remittance basis once Irish resident, but it covers foreign investment income and gains kept abroad, not work performed in Ireland or Irish income. The UK rules also continue after departure: the inheritance tax tail for long-term residents, temporary non-residence for gains, and section 832A for pre-departure foreign income remitted to the UK.

### Is employment income covered by Ireland's remittance basis?

Not where the duties are performed in Ireland. Income from an employment exercised in Ireland is taxable in Ireland whether the employer is Irish or foreign and wherever the salary is paid. The relief designed for inbound employees is the Special Assignee Relief Programme, which has its own salary threshold and conditions, rather than the remittance basis.

### When does Irish gift and inheritance tax apply to a non-domiciled person?

Irish-situated property is within Capital Acquisitions Tax from the start. For foreign assets, a non-domiciled individual is treated as resident for the tax only after five consecutive tax years of Irish residence. The rate is 33% above lifetime group thresholds, and for gifts and inheritances taken on or after 7 October 2026 the threshold for a child receiving from a parent is €420,000.

### Does moving to Ireland end UK inheritance tax?

Not immediately for a long-term UK resident. Someone resident in the UK for 10 of the previous 20 tax years remains within UK inheritance tax on a worldwide estate for three to ten tax years after leaving, depending on how long they were resident. The UK and Ireland have a convention on estates and gifts that gives relief by credit where both countries tax the same transfer.

### What is the Irish domicile levy?

It is an annual €200,000 levy on individuals who are Irish domiciled and have worldwide income above €1 million, Irish property worth more than €5 million and Irish income tax below €200,000 in the year. Irish income tax paid can be offset against it. It does not apply to someone who is not domiciled in Ireland, so it is not a cost of the non-dom regime.

---

**Critical advisory.** Ireland's remittance basis is the last regime of its kind in the corridor, and it is being read by UK families as a way to carry the old UK rules across the Irish Sea. It does less than that. It protects foreign investment wealth kept abroad, for as long as a foreign domicile can be shown, and it does not touch Irish work, Irish property, gifts after year five, or the UK tax that follows a long-term resident for up to ten years. In my experience the families who regret a move to Ireland did not misunderstand the Irish rules.

They planned only one side of the move. We map the UK exit and the Irish arrival together, separate the accounts before the first day of residence, and time the sales and the gifts against both clocks. If you are considering a move from the UK to Ireland, speak to us through our [services page](https://www.boruconsulting.com/services) before the year of departure begins. This article is general information about UK and Irish law as at 11 November 2026 and not legal or tax advice; your own position should be confirmed against your specific facts before you act.

## Glossary concepts in this article
- [Inheritance Tax (IHT)](https://www.boruconsulting.com/glossary/inheritance-tax): A UK tax charged on the value of a person’s estate on death, and on some lifetime gifts, above a tax-free threshold.
- [Non-Domiciled Status (Non-Dom)](https://www.boruconsulting.com/glossary/non-domiciled-status): A UK tax status for someone who is resident in the UK but treats another country as their permanent home.
- [Remittance Basis](https://www.boruconsulting.com/glossary/remittance-basis): The former UK regime under which a non-domiciled resident was taxed on foreign income and gains only when they were brought into the UK, rather than as they arose.
- [Special Assignee Relief Programme (SARP)](https://www.boruconsulting.com/glossary/special-assignee-relief-programme): An Irish relief that lets an employee relocating to Ireland exempt 30% of their employment income above a threshold from income tax, for up to five years.
- [Temporary Non-Residence](https://www.boruconsulting.com/glossary/temporary-non-residence): A UK anti-avoidance rule that taxes certain income and gains realised during a short period of non-residence once the person resumes UK residence.

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Source: https://www.boruconsulting.com/blog/ireland-non-dom-tax-regime