Irish taxes

[AmythestBangle]

Can anyone help me regarding tax/double taxation. To put a situation as simply as I can: I live in Ireland at present but am UK domicile. All money I earn is earned in the UK (I am self employed professional). I pay taxes in the UK on all income. A certain amount of money I bring into Ireland to live on. What tax do I pay on that money in Ireland, given I have already been fully taxed on it in the UK. ie do I pay any Irish tax at all in the end?

Thank you so much.

This is the best information to give you :
Cross border workers in Ireland

You need a good accountant, a company based near the NI border will have lots of experience with this.

Do you work in NI or in GB? I think the cross border legislation only applies to those working in the North.

The short answer though is yes you will pay more tax. At a minimum it will be topping up to the Irish tax rates for the money you have brought over. And if you are paying yourself in UK dividends be prepared for a shock as there isn't the same favourable treatment.

Hi, thanks for the replies. I don't work in NI, my work is all in GB. It is mostly done remotely though, from all over place, but my business address is in London.

I do have an accountant, my concern is that she is getting this wrong as I seem to be paying enormous amounts of tax on the money I bring into Ireland, which has all already been taxed by HMRC. I feel I need to find out more myself rather than just relying on her. She is also retiring so I am looking for a new accountant, and I want to appear a bit more clued up than I am when talking to them.

Are you PAYE in the UK? If not there will be a big lump of top up tax. And if you are PAYE the tax bands in Ireland are different so you'll have a smaller top up lump to pay.

GB and Irish tax isn't over familiar to most Irish accountants so I really recommend finding one which operates cross Border. Try Dundalk or Cavan or Letterkenny based accountants.

No not PAYE, freelance/self-employed.

That will be why you are paying lots of top up tax in Ireland. Dividends are taxed much higher in Ireland.

Dividend income https://share.google/kbiiy9vEGDIRuNiA2

I'm not a company though!

That sounds like nonsense that you are paying tax twice when there's a double tax agreement between Ireland and the UK. I live in Ireland and all my money is in the UK - I pay UK tax and just transfer living expense money. I've read noting to indicate I should also pay Irish tax

https://www.citizensinformation.ie/en/moving-country/working-in-ireland/migrant-workers/coming-to-ie-tax/

This explains double taxation in simple terms.

There is an agreement between Ireland and the UK.
I'm not sure GiddyKiddy is correct that no tax at all is due on money transfered from taxed income in the UK to Ireland, but you certainly don't pay full UK taxes and full Irish taxes.
The actual agreement and explanations are on both Revenue.ie and HMRC sites but the citizens advice site gives a basic explanation which may help you when discussing your particular situation with a tax accountant.

Thanks for massages everyone. We have done a lot of reading and research and it turns out we have been charged far too much tax and that our accountants basically really dropped us in it over the past 5 years. We should only have been declaring to Irish Revenue the money remitted to Ireland ie what we have been living on here, NOT the UK income as well (which is all already taxed in the UK). And in Ireland we only have to pay what is due on that money under Irish taxes minus what we have already paid in UK tax on that money (which is a bit more as Irish taxes are slightly more than UK).

I am absolutely furious with the accountants (a large multinational firm whom I thought I could trust) and we are having a big meeting with them next month. Meanwhile, our tax return for 2024 (which went in yesterday) is a tiny percentage of what we have paid every other year since we have been here (as in less than 10%). We are going to have to look into getting the literally hundreds of euros of overpaid tax back (and I am thinking of suing the accountants).

@Giddykiddy you do have to declare the remittance brought into Ireland, certainly. And then take the UK taxes paid off the tax on that remittance to get what is owed in Ireland.

You can apply for 4 years previous taxes back also OP so if you are puting in now for 2024 ask them to do same for previous 4 years also.

They put in the tax return yesterday, but I will be asking them to do the recalculations asap. They had better not try and charge me for the work. I nearly went bankrupt and my anxiety disorder went through the roof a couple of years ago because of the tax burden (I was literally paying 90% of my income in taxes between the UK and Ireland). I cannot understand how they got it so wrong. They knew very well my domicile was UK!

Your domicile has little to do with your tax personal situation as it will mainly be on when your resident and ordinarily resident status changed from the UK to Ireland and the nature of your UK contracts.

You are carrying out a trade/profession by providing services into another tax system (the UK) while you remain living in Ireland so you accountant needs to explain how your Irish generated income falls outside the Irish tax net.

Your accountant should have provided you with the workings of how they were breaking out your Irish and UK income flows plus why and how they are applying the doube taxation tax credits plus what your status is in regards to any social insurance or pension payments.

That was before they filed anything on your behalf.

As you intend to return to live in the UK your NI payments would give you access to medical and other OAP provisions and PRSI payments would cover "current" social provision access. If this has not already come up you need to discuss if you can reclaim any payments

Well I have now been told that domicile makes an enormous difference, if I am non-dom in Ireland I only pay tax on the money I remit into Ireland, but if I was to be Irish domiciled I would pay tax on worldwide income, and that is the basis on which they are now calculating it. My/our income is all on work I have done in the UK. I have also apparently not been supposed to have been required to pay full PRSI as I would not be able to get any pension from it. I will have a full UK pension when I get to that age.

PS I have no Irish generated income whatsoever.

There is a difference in Irish law between domicile and residency for tax. And if you are Irish in Ireland you are domiciled. They treat all your global income as if it was earntin Ireland.
The extra tax is based on what isn't taxed in the UK under your personal allowance there plus any other differences.

Tax residence and domicile in Ireland https://share.google/x5qCuTMNWfzOAyWwn

I'd certainly threathen legal action!

You have to prove that your economic activity is not income generated by you in Ireland.

What tax rule and case law have you to back up your assumption that you are not just selling into the UK?

You live in Ireland full time.
You are a sole trader so ownership and control is you doing your thing.
Your contracts most likley qualify as being executed in Ireland even if they have a subject to legal action in the UK courts clause.
You are controlling your business activity from Ireland.
If being sued your home address is in Ireland and what ever London postal service address you may be providing.
Unless you are renting your Irish property can be used to secure outstanding court settlements.

You need to go back to basics.

When you moved to live in Ireland full time 5 years ago you became a tax resident from the final move date and remained 100% liable for UK tax.

Your tax accountant should have explained when and how you become ordinarily resident in Ireland and lost this in the UK.

Then look at your profession and what specific rules apply.

The tax position should have been explained when you were taken on as a client. If you have documents from the prior years you should check what was covered in writing.

Check the document supporting each tax filings. I would expect a calculation to double check day counts to make sure you qualified as living in Ireland for the required days and how the Uk tax credit was calculated and if there were any extra Irish tax credits etc

I'm not Irish, born in London, lived in London most of my life, I earn every penny of my income in the UK, including my private pension.