Global

Details

  • Service: Tax, Global Mobility Services
  • Type: Regulatory update, Survey report
  • Date: 1/4/2014

Income Tax 

Taxation of international executives
Tax returns and compliance
Tax rates
Residence rules
Termination of residence
Economic employer approach
Types of taxable compensation
Tax-exempt income
Expatriate concessions
Salary earned from working abroad
Taxation of investment income and capital gains
Additional capital gains tax (CGT) issues and exceptions
Tax reimbursement methods
Relief for foreign taxes
General tax credits
Sample tax calculation


All income tax information is summarized by KPMG, the Irish member firm of KPMG International, based on the revenue commissioners of Ireland.


Tax returns and compliance

When are tax returns due? That is, what is the tax return due date?


31 October following the year of assessment


What is the tax year-end?


31 December


What are the compliance requirements for tax returns in Ireland?


Residents


Every self-assessed individual is liable to pay Irish income tax or capital gains tax for any tax year-ending 31 December and is required to make a return of income and/or chargeable capital gains to the Irish Revenue no later than the 31 October following the relevant tax year.


Individuals who have no income or gains other than employment income subject to withholding Pay-As-You-Earn (PAYE) are generally not required to submit a tax return.


For the 2014 tax year, a tax return is due to be filed no later than 31 October 2015. Extension to the filing and payment date may be available where the individual uses the Revenue Online Service (ROS) web site of the Irish Revenue to both submit his/her tax return and make electronic tax payments from a designated bank account. Individuals who do not use the facility are subject to the main filing deadline indicated (31 October). Failure to file a tax return within two months of the relevant filing date results in an automatic penalty equal to 5 percent of the income tax and/or capital gains tax liability due before deduction of any preliminary tax paid for the tax year. The late filing penalty increases to 10 percent thereafter.


Individuals subject to tax under the self assessment system are required to make a balance of income tax payment by 31 October following the end of tax year together with an estimated preliminary (income) tax payment for the current tax year. For 2014, a preliminary income tax payment is due no later than 31 October 2014, 2014 balance of tax is payable by 31 October 2015. The required limits for the preliminary income tax payments are as follows:


  • 100 percent of the income tax liability for the previous tax year
  • 90 percent of the income tax liability for the current year
  • 105 percent of the income tax liability of the pre-preceding tax year where payment is made via direct debit. (This option may only be chosen where the individual had a tax liability for pre-preceding tax year.)

Capital gains tax for disposals made during the period 1 January to 30 November is due by 15 December of that tax year. Capital gains tax on disposals of assets during the period 1 December to 31 December must be paid by 31 January following the end of the relevant tax year. The relevant transactions are also reportable on the annual tax return relating to the year of disposal.


Failure to make tax payments on time, or within the required limits, results in interest penalties effective from the due date for payment.


If an individual (other than a director of an Irish company) does not have income that is taxed otherwise than under the PAYE system, there is no requirement to file a tax return unless he/she has chargeable capital gains during the tax year Generally, all Irish company directors must make returns even if taxed only under the PAYE system.


Non-residents


Non-residents are liable to Irish tax on Irish-source income only (subject to DTA relief).


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Tax rates

What are the current income tax rates for residents and non-residents in Ireland?


Residents


Income tax table for 2014


Taxable income bracket (single person) Total tax on income below bracket Tax rate on income in bracket
From EUR To EUR EUR Percent
0 32,800 6,560 20
32,801 Over 0 41

Non-residents


Income tax table for 2013


Taxable income bracket (single person) Total tax on income below bracket Tax rate on income in bracket
From EUR To EUR EUR Percent
0 32,800 6,560 20
32,801 Over 0 41

Universal social charge


The Universal Social Charge, which came into effect on 1 January 2011, is a levy payable on gross income, including notional pay, before any relief for any capital allowances, losses or pension contributions.


All individuals are liable to pay the universal social charge if their gross income exceeds the threshold of EUR10,036. In the case of individuals aged 70 or over, and individuals who hold full medical cards, the 4 percent rate applies to all income over EUR10,036. This reduced rate however is only available for those whose gross income is less than EUR60,000 per annum.


The USC is essentially another form of income tax and is usually regarded as an admissible tax for the purposes of Ireland’s Double Taxation Agreements.


Per year Rate of universal social charge
EUR Percent
Up to EUR10,036 2
Between EUR10,036 and EUR16,016 4
In excess of EUR16,016 7

There is a surcharge of 3 percent on individuals who have income from self employment that exceeds EUR100,000 in a year regardless of age.


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Residence rules

For the purposes of taxation, how is an individual defined as a resident of Ireland?


Residence is based solely on physical presence in Ireland. Residency is acquired in respect of a tax year where an individual spends either of the following:


  • 183 days in Ireland during that tax year
  • aggregates 280 days in Ireland over two consecutive tax years with at least presence of 30 days in the second tax year.

Under the aggregation test, the individual is regarded as resident for the second tax year. An individual is considered present in Ireland if they spent any part of that day in Ireland.


Ordinary residence begins once an individual has been resident in Ireland for three consecutive tax years. Similarly, it ceases at the end of the third consecutive year in which an individual is not resident.


Irish Individuals who are no longer resident but who retain ordinary residence and are Irish domiciled are taxable on worldwide income subject to certain exclusions. Excluded income includes; income from an employment, trade, or profession the duties of which are exercised wholly abroad and foreign investment income not exceeding EUR3,810 during a tax year. Where annual foreign income exceeds EUR3,810, the total amount of such income remains taxable in Ireland subject to relief under a tax treaty.


Is there, a de minimus number of days rule when it comes to residency start and end date? For example, a taxpayer can’t come back to the host country for more than 10 days after their assignment is over and they repatriate.


No.


What if the assignee enters the country before their assignment begins?


Each case should be considered on its own merits.


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Termination of residence

Are there any tax compliance requirements when leaving Ireland?


There are no special procedures on the termination of residence.


What if the assignee comes back for a trip after residency has terminated?


Each case should be considered on its own merits.


Communication between immigration and taxation authorities


Do the immigration authorities in Ireland provide information to the local taxation authorities regarding when a person enters or leaves Ireland?


Yes.


Filing requirements


Will an assignee have a filing requirement in the host country after they leave the country and repatriate?


Each case should be considered on its own merits. In general, a tax return will be required if the assignee has Irish-source income.


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Economic employer approach1

Do the taxation authorities in Ireland adopt the economic employer approach to interpreting Article 15 of the OECD treaty? If no, are the taxation authorities in Ireland considering the adoption of this interpretation of economic employer in the future?


Traditionally no, but it is understood Revenue may review this position in the near future.


De minimus number of days2


Are there a de minimus number of days before the local taxation authorities will apply the economic employer approach? If yes, what is the de minimus number of days?


Not applicable.


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Types of taxable compensation

What categories are subject to income tax in general situations?


All benefits, whether in-cash or in-kind, arising from an employment form part of taxable income, subject to certain exceptions. The following are examples of remuneration that would be included as income for tax purposes:


  • reimbursement of taxes
  • reimbursement of school fees
  • cost-of-living allowances
  • housing allowances and housing provided by the employer on a non-arms length basis
  • moving allowances (but excluding direct reimbursement of expenses incurred in moving to take up a new employment)
  • use of company car
  • the benefit of loans at reduced or zero interest rates provided directly or indirectly by the employer
  • round sum expense allowances
  • medical insurance or other medical benefits provided by the employer
  • any sums paid by the employer to provide pension or other retirement benefits, except where such sums are paid under a pension scheme approved by the revenue commissioners
  • share options (except options granted under a scheme for which revenue approval has been granted).

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Tax-exempt income

Are there any areas of income that are exempt from taxation in Ireland? If so, please provide a general definition of these areas.


The following items are not subject to tax:


  • contributions by an employer to an Irish revenue approved pension scheme
  • foreign pension contributions in certain circumstances
  • contributions by an employer to an Irish revenue approved profit sharing scheme
  • certain relief is available in respect to non-contractual payments made in connection with the termination of an employment
  • provision by an employer of a travel (bus or train) pass to employees or directors of the company
  • provision of bicycles for employees and directors aimed at encouraging more employees to cycle to and from work.

With effect from 1 January 2007, the Revenue commissioners are prepared to accept that tax free subsistence that relates to the provision of accommodation and utility charges may be paid or reimbursed for the first 12 months of a temporary assignment provided that the period of assignment in Ireland does not exceed 24 months.


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Expatriate concessions

Are there any concessions made for expatriates in Ireland?


Special Assignee Relief Programme (SARP)


A Special Assignee Relief Programme (SARP) was introduced in 2012 which applies to individuals arriving in Ireland during 2012, 2013 or 2014. The relief operates on the basis of providing a tax free deduction from remuneration based on a formula as follows:


(A-B) X 30%


Where A is the total renumeration of the employee with a cap of up to EUR500,000 and B is EUR75,000


The following conditions must be met.


  • The employee must have been employed by a non Irish company for 12 months prior to arriving in Ireland. This employer must be incorporated and tax resident in a country with which Ireland has a tax information exchange agreement.
  • The employee can be seconded to work in Ireland under his/her existing employment contract or be employed directly by an Irish Group company.
  • Substantially all of the employee’s duties must be performed in Ireland for at least 12 consecutive months.
  • The relief will apply for the first five years of the individual’s residency in Ireland.

Foreign Earnings Deduction (FED)


In 2012 a Foreign Earnings Deduction (FED) for employees who travel to develop markets in BRICS countries namely Brazil, Russia, India, China and South Africa. The FED will apply for the tax years 2012, 2013 and 2014 only. The deduction will apply to an Irish resident individual who has 60 qualifying days working outside Ireland in the BRICS countries in a continuous 12 month period. A qualifying day is one of at least 4 consecutive days throughout the whole of which the individual is performing the duties of his employment in any of these countries. The recent Finance Bill 2013 extends the application of the FED relief to Algeria, the Demographic Republic of Kenya, Nigerai, Senegal and Tanzania.


The FED is calculated based on the following formula:


Number of qualifying days in a year of assessment x Qualifying Income


Aggregate number of days in the year of assessment that the individual held a relevant employment.


Qualifying income excludes remuneration in the form of benefits in kind. Share remuneration is included. The income qualifying for FED is capped at a maximum of EUR35,000.


Remittance Basis


An expatriate who is resident in Ireland but not domiciled is not liable to Irish tax on income from a foreign employment performed outside of Ireland, unless it is remitted into Ireland.


The remittance basis also extends to foreign investment income/capital gains in the case of non domiciled individuals.


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Salary earned from working abroad

Is salary earned from working abroad taxed in Ireland? If so, how?


Please see previous discussion, as remittance basis may apply, where an individual is resident, non domiciled and working under a non Irish employment contract.


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Taxation of investment income and capital gains

Are investment income and capital gains taxed in Ireland? If so, how?


Rents derived from an Irish property are liable for Irish taxes regardless of the residency position of the recipient. For resident and domiciled individuals, rents from worldwide properties are subject to Irish taxes (subject to certain exemptions). Individuals’ resident but not domiciled in Ireland will be taxed on Irish rental income in full, and rents derived from other foreign properties if remitted to Ireland.


When calculating assessable rental income, most expenses incurred in renting the property are deductible. Such expenses would include agents’ fees, advertising costs, repairs etc. If the property is furnished, either an annual wear and tear allowance of EUR254 or an allowance equal to 12.5 percent of the total cost of the fixture and fittings, whichever is the higher, is available. A deduction is available against gross rents for mortgage interest paid on borrowings for the purchase, improvement or repair of a rental property. A claim for mortgage interest has been reduced to 75 percent from 8 April 2009. This measure applies to both new and existing mortgages.


The entitlement to a reduction for mortgage interest paid against rental income is also conditional on compliance with the registration requirements of the Residential Tenancies Act 2004.


The Private Residential Tenancy Board (PRTB) was established to operate a national tenancy registration system, to provide information and policy advice on the private rented sector. Landlords are now required to register details of all of their tenancies within one month of the commencement of the tenancy. The tenancy must be registered with the PRTB and the appropriate registration fee paid. A form PRTB1 should be completed and submitted to the PRTB in this regard. In certain instances, Irish residents can claim an exemption of up to EUR10,000 on rental income received from a room, which is made available as rented residential accommodation in a principal private residence. Where annual rental income exceeds this amount all rental income received during the tax year is taxable subject to the deductions available as outlined. Certain conditions need to be satisfied in order to exclude this type of rental income from Irish tax; namely, the occupation of the property by the taxpayer wholly as his/her sole residence throughout the tax year. This exemption is therefore not available to individuals on assignment from Ireland during a tax year. The exemption is also not available where the rent is paid to an employee/office holder of the person making the payment.


Dividends and interest income are taxable as part of total income. Individuals’ resident but not domiciled in Ireland and in receipt of investment income from sources outside Ireland will only be taxable to the extent that the income is remitted into Ireland.


Dividends from Irish resident companies carry a tax credit in the form of dividend withholding tax, which is included in total income but is deductible from income tax payable. Double taxation relief is available in respect of foreign withholding tax on foreign (non-U.K.) dividends received under a relevant tax treaty. In the case of a non-domiciled individual, no credit is available for foreign dividend withholding tax unless the dividend is remitted into Ireland. Interest paid by Irish banks, building societies, and similar financial institutions (including Irish branches of foreign banks) are subject to Deposit Interest Retention Tax (DIRT) (30 percent for 2012). No additional income tax is payable on the interest regardless of the individuals marginal tax rate but Universal Social Charges may be payable. A non-resident person is entitled to exemption from this withholding tax if the appropriate non-resident’s declaration is made to the bank or other financial institution.


Individuals are liable to capital gains tax on chargeable gains, that is, capital gains as computed in accordance with the rules prescribed in the Irish Capital Gains Tax Acts. An individual, resident and domiciled in Ireland, is liable to capital gains tax on worldwide chargeable gains. An individual, who is resident but not domiciled in Ireland, is liable on chargeable gains from Irish situated assets, but not on chargeable gains from other assets if the proceeds of the disposal are not remitted into Ireland.


Non-resident and non-ordinarily resident individuals are liable on chargeable gains from the disposal of certain Irish specified assets, but not on the disposal of any assets situated outside Ireland. The main assets on which a non-resident is liable are Irish land, buildings and interests in such land (such as a leasehold interest or mineral rights).


Certain specified assets are exempted so that capital gains from their disposal are not chargeable gains. Exempted assets include an individual’s principal private residence (but not a second home), Irish government securities, most life assurance policies, tangible movable assets with a predictable life of less than 50 years (such as a racehorse).


In the case of a gain on the disposal of a principal private residence carrying development value (sale value in excess of current use value), the exemption does not apply to the part of the gain attributable to the increase in the development value since the date of acquisition.


Chargeable gains are calculated after making an indexation adjustment to the base cost to allow fully for inflation between the year of acquisition and the year of sale. However, in the case of gain on the disposal of Irish situated land or buildings carrying development value, only the current use value at the date of acquisition is indexed. Indexation (relief for inflation) does not apply after 31 December 2002. Any individual liable to capital gains tax is exempted from the first EUR1,270 of chargeable gains in each tax year. There is no transfer of any unutilized allowance between married couples.


The rate of capital gains tax is 33 percent except for gains arising from the sale of certain foreign life assurance policies and units from offshore funds not based in either the EEA or in an OECD country with which Ireland has a double tax agreement.


Dividends, interest, and rental income


Interest


In general, deposit interest received from Irish or EU lending institutions is liable to Irish income tax at 41 percent with effect from 1 January 2014.


Dividends


Withholding tax at the standard rate applies to distributions made by an Irish resident company.


Gains from stock option exercises


Residency status Taxable at:
Grant Vest Exercise
Resident N N Y
Non-resident N N Y/N
Other (if applicable) N/A N/A N/A

Foreign exchange gains and losses


Not applicable.


Principal residence gains and losses


A gain accruing to the an individual on the disposal of a his/her private residence and grounds up to one acre which has been occupied by the individual throughout the period of ownership as his/her only or main residence is exempt from Irish capital gains tax.


Partial relief is available on gains on the disposal of a property which was an individual’s principle residence for part of the period of ownership only. In addition, certain periods of absence may be regarded as periods of occupation for the purposes of calculating the relief such as, the last 12 months of ownership, periods of foreign employment if the individual occupies the residence both before and after the periods.


Capital losses


Chargeable gains for a year of assessment are aggregated with allowable losses for the year in computing the net amount assessable to capital gains. Losses may also be brought forward from previous years. Allowable losses which remain unrelieved may be carried forward indefinitely.


Personal use items


Depends on the nature of the item.


Gifts


Assets acquired by inheritance or gift are deemed to have been acquired at market value at the date of the death or gift.


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Additional capital gains tax (CGT) issues and exceptions

Are there additional capital gains tax (CGT) issues in Ireland? If so, please discuss?


Capital gains exit tax


Anti-avoidance legislation has been introduced in respect of temporary non-residents who dispose of certain assets during a tax year of non-residence for the purpose of avoiding Irish capital gains tax. It applies with respect to the 2003 tax year onwards.


For the restriction to apply, an individual must beneficially own relevant assets on the 31 December of the tax year of departure. These are defined as shares in a company or a right to acquire shares or other rights in a company. The market value of the relevant assets on this date must be equal to or exceed either 5 percent of the value of the issued share capital of the company or EUR500,000 for the restriction to apply.


Where an individual leaves Ireland and during a period of non-residence sells relevant assets but returns to Ireland within six tax years of departure, the individual is deemed to have disposed of and immediately reacquired the relevant assets as at the 31 December of the tax year of departure at the market value on that date. Any chargeable gain accruing must be included in the tax return applicable for the year of return.


This legislation will not apply where, as a resident of Ireland, the individual would not have been assessable to Irish capital gains tax in respect of gains on a disposal of relevant assets.


Are there capital gains tax exceptions in Ireland? If so, please discuss?


Pre-CGT assets


Not applicable.


Deemed disposal and acquisition


Not applicable.


Local Property Tax


An annual self assessed Local Property Tax (LPT) charged on the market value of all residential properties in Ireland (whether rented or occupied) is now in force in Ireland. A half year charge applied in 2013 with a full year charge applying in 2014 and thereafter. The LPT charge for a property is based on the market value on the “valuation date”. The charge ranges from €90 per annum (for properties valued under €100,000 on the valuation date) to €3,050 for properties values at €1.5m or more on the valuation date.


For 2013, the valuation date was 1 May 2013. For 2014, the “valuation date” was 1 November 2013.


In order to be within the charge to LPT for 2014, an individual must own (co-own or have an interest in) the property on the valuation date.


Payment of the tax can be made via the payroll system on a monthly basis or via direct debit or once off payments directly to the Irish Revenue.


General deductions from income


What are the general deductions from income allowed in Ireland?


The only deductions allowed in computing income from an employment are in respect of expenses incurred by the employee wholly, necessarily and exclusively in the performance of the duties of the employment. In practice it is very difficult to obtain a deduction on this basis. In any case, it is usual for the employer to reimburse such expenses directly to the employee.


Most allowances are now granted by way of a tax credit.


2014 tax credits EUR
Single/separated 1,650
Married couple 3,300
Widowed (no children) 1,650
Home carer 810
Employment (PAYE) 1,650

The home carers’ credits is claimable by married persons who are jointly assessed and where one spouse works at home to care for children, the aged or incapacitated persons. The carer spouse’s income is not in excess of EUR5,080. A reduced tax credit applies where the income is between EUR5,080 and EUR6,750.


The credit and the increased standard rate band for certain two earner couples are mutually exclusive but a person may opt for whichever is the more beneficial.


The employee PAYE credit is only available to Irish employment income or other EU employment income, which is subject to a similar system of wage withholding.


A deduction is available for alimony made pursuant to a court order. Such payments constitute taxable income (from which the payer deducts tax at the standard rate) of the recipient. No deductions are available for maintenance paid in respect of child support.


In general, a deduction from total income is given for interest paid on any loan used to purchase, repair, develop, or improve an individual’s principal private residence.


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Tax reimbursement methods

What are the tax reimbursement methods generally used by employers in Ireland?


Current year gross-up is the normal method of recognizing tax reimbursements paid by the employer.


Calculation of estimates/prepayments/withholding


How are estimates/prepayments/withholding of tax handled in Ireland? For example, Pay-As-You-Earn (PAYE), Pay-As-You-Go (PAYG), and so on.


Each individual, other than one whose income is fully taxed under the Pay-As-You-Earn (PAYE) system, is required to make a prepayment, known as preliminary tax. In order to avoid interest, the amount of preliminary tax paid must be of an amount at least equal to the lesser of the following:


  • 90 percent of the tax due for the year as determined after the tax return has been filed
  • 100 percent of the individual’s tax liability for the immediately preceding tax year
  • 105 percent of the income tax liability of the pre-preceding tax year where payment is made via direct debit. (This option may only be chosen where the individual had a tax liability for pre-preceding tax year).

In determining the preliminary tax payment under each of these tests, the relevant percentage is applied to the aggregate of the individual’s liabilities to income tax, PRSI and USC. However, any of these taxes or levies that have been withheld by an employer under the PAYE system is credited before applying the relevant percentage.


In practice, the Irish Inspector of Taxes may issue a notice stating the amount of preliminary tax that the inspector thinks is likely to be due based on the previous year’s tax return. The amount in the Inspector’s notice becomes payable on the preliminary tax due date unless the individual displaces the inspector’s figure by paying his/her own estimate before that date. The individual is not required to make any preliminary tax payment for a year if his/her liability to Irish tax (excluding tax under PAYE) for the preceding year was zero. For example, an expatriate starting to work in Ireland has no preliminary tax to pay in the first tax year in which he/she is a resident. However, such a person has the normal obligation to make a tax return and pay his/her tax liability after the end of that year.


Pay-as-you-earn (PAYE) withholding


Calculated on monthly cash remuneration and benefits-in-kind.


PAYE instalments


Generally, paid monthly.


When are estimates/prepayments/withholding of tax due in Ireland? For example, monthly, annually, both, and so on.


Monthly.


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Relief for foreign taxes

Is there any Relief for Foreign Taxes in Ireland? For example, a foreign tax credit (FTC) system, double taxation treaties, and so on?


Normally, relief for foreign income tax suffered on any income is granted as a credit against the Irish income tax on the same income. A credit is only available under the following circumstances:


  • the recipient of the income is resident in Ireland for the relevant tax year
  • the income is derived from a country with which Ireland has a tax treaty.

Ireland has currently 70 tax treaties (of which 68 are in effect) with most major countries.


An individual resident but not domiciled in Ireland is not allowed a credit for foreign tax to the extent that it is attributed pro rata to foreign income not remitted into Ireland.


The only form of unilateral relief from double taxation given is by deducting the foreign tax from the relevant foreign income. Unilateral relief is given for foreign tax suffered on income not covered by a tax treaty and may, if the taxpayer elects, be taken instead of a tax credit available under a tax treaty.


Similarly, relief for any foreign tax suffered on any chargeable capital gain is given against Irish capital gains tax on the same chargeable gain, but only where permitted under a tax treaty. If not so permitted, unilateral relief is available in calculating the chargeable gain in the form of a deduction of the foreign tax.


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General tax credits

What are the general tax credits that may be claimed in Ireland? Please see list below.


  • single
  • married
  • home carer’s allowance
  • employee tax credit
  • rent relief - this no longer applies in relation to new leases taken out after 7 December 2010
  • widow
  • one parent
  • medical insurance (if paid gross by employer)
  • deposit interest retention tax (DIRT)
  • dividend withholding tax (DWT)
  • college fees
  • gift to approved bodies- From I January 2010 tax relief is allowable for donations made to charities established in EEA and European Free Trade Association.

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Sample tax calculation3

This calculation assumes a married taxpayer resident in Ireland with two children whose three-year assignment begins 1 January 2012 and ends 31 December 2014. The taxpayer’s base salary is USD100,000 and the calculation covers three years.


2012
USD
2013
USD
2014
USD
Salary 100,000 100,000 100,000
Bonus 20,000 15,000 10,000
Cost-of-living allowance 10,000 10,000 10,000
Housing allowance 12,000 12,000 12,000
Company car 6,000 6,000 6,000
Moving expense reimbursement 20,000 0 10,000
Home leave 0 5000 0
Education allowance 3,000 3,000 3,000
Interest income from non-local sources 6,000 6,000 6,000

Exchange rate used for calculation: USD1.00 = EUR0.7860.


Other assumptions


  • All earned income is attributable to local sources.
  • Bonuses are paid at the end of each tax year, and accrue evenly throughout the year.
  • Interest income is not remitted to Ireland.
  • The company car is used for business and private purposes and originally cost USD20,000.
  • The employee is deemed resident throughout the assignment.
  • Tax treaties and totalization agreements are ignored for the purpose of this calculation
  • Moving expense reimbursement is not taxable as relocation expenses meeting certain conditions are exempt.
  • The individual’s spouse and children accompany him on assignment and the spouse is not in receipt of any income which is taxable in Ireland.

Calculation of taxable income


2012
EUR
2013
EUR
2014
EUR
Days in Ireland during year 365 365 365
Earned income subject to income tax
Salary 78,600 78,600 78,600
Bonus 15,720 11,790 7,860
Cost-of-living allowance 7,860 7,860 7,860
Net housing allowance 9,432 9,432 9,432
Company car 4,716 4,716 4,716
Moving expense reimbursement 0 0 0
Home leave* 0 0 0
Education allowance 2,358 2,358 2,358
Interest income from non-local sources** 0 0 0
Total taxable income 118,686 114,756 110,826

Calculation of tax liability


2012
EUR
2013
EUR
2014
EUR
Taxable income as above 118,686 114,756 110,826
Irish tax thereon 0 0 0
Less:
Domestic tax rebates (dependent spouse rebate) 0 0 0
Foreign tax credits 0 0 0
Total Irish tax 34,933 33,322 31,711
Total USC 7,627 7,352 7,077

* It is assumed that the home leave amount is exclusive of one home leave trip per year and therefore not taxable.


** It is assumed that the other income represents non-Irish income which has not been remitted to Ireland and therefore not taxable.


It is assumed that an A1/Certificate of Coverage has been obtained; therefore Irish social security contribution has not been included 2012.




1Certain tax authorities adopt an "economic employer" approach to interpreting Article 15 of the OECD model treaty which deals with the Dependent Services Article. In summary, this means that if an employee is assigned to work for an entity in the host country for a period of less than 183 days in the fiscal year (or, a calendar year of a 12-month period), the employee remains employed by the home country employer but the employee’s salary and costs are recharged to the host entity, then the host country tax authority will treat the host entity as being the "economic employer" and therefore the employer for the purposes of interpreting Article 15. In this case, Article 15 relief would be denied and the employee would be subject to tax in the host country.


2For example, an employee can be physically present in the country for up to 60 days before the tax authorities will apply the ‘economic employer’ approach.


3Sample calculation prepared by KPMG, the Irish member firm of KPMG International, based on the revenue commissioners of Ireland.




© 2014 KPMG, an Irish partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative ("KPMG International"), a Swiss entity. All rights reserved.

 

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Taxation of international executives