International Tax

Business Operations in the Republic of Ireland (Portfolio 7170)

  • Tax Management Portfolio, Business Operations in the Republic of Ireland, No. 7170, addresses in general terms the main legal, tax, and employment aspects of carrying on a business in Ireland.


Tax Management Portfolio, Business Operations in the Republic of Ireland, No. 7170, addresses in general terms the main legal, tax, and employment aspects of carrying on a business in Ireland. Chapter I of the Portfolio provides some general background information on Ireland. Chapter II outlines the general background in which businesses are operated, and the business financing, state aid and grant programs available; it also addresses various legal matters that affect business operations in Ireland, in particular trade and commerce regulations (to include in relation to imports and exports, anti-trust, intellectual property, e-commerce, data protection, communications and broadcasting regulations), labor regulations and real estate, construction, planning and environmental law. Chapter III discusses the various forms of doing business in Ireland (i.e., the different types of corporate or legal entity) and the requirements that apply in relation thereto.

Chapters IV to XVI inclusive provide a comprehensive review of the Irish taxation system and its effect on business operations in Ireland. In particular, the taxation of domestic corporations, foreign corporations, branches, individuals and partnerships is addressed. There are also specific chapters on other taxes, intercompany pricing, the special provisions relating to multinational corporations, Ireland as a location for the operations of multinational corporations, avoidance of double taxation and anti-avoidance.

The Table of Worksheets include links to:

• The form of Constitution set out in the Irish companies legislation in relation to various types of corporate entity;
• Many of the most common Irish taxation return, claim, application and other forms, in respect of corporations, individuals and partnerships;
• Guidance that has been issued by the Revenue Commissioners on certain matters;
• The tax treaty between the United States and Ireland, the tax treaty between the United Kingdom and Ireland, the protocols thereto and commentaries thereon;
• A list of the tax treaties that Ireland has entered into and a table of withholding tax rates that apply thereunder; and
• Other relevant corporate and tax documents.

Note: In this Portfolio, the phrase “tax treaty country” is used to refer to a country with which Ireland has entered into a double taxation agreement. The phrases “tax treaties” and “double taxation agreements” are used interchangeably. The Irish Revenue Commissioners are referred to herein as Revenue or the Revenue.

This Portfolio may be cited as Ryan, O’Shea, and Fahy, 7170 T.M., Business Operations in the Republic of Ireland.

Table of Contents

I. Ireland — Constitutional, Political, and General Background
II. Operating a Business in Ireland
III. Forms of Doing Business in the Republic of Ireland
IV. Introduction to Irish Taxation and Principal Taxes
V. Taxation of Domestic Companies or Corporations
VI. Taxation of Foreign Corporations
VII. Taxation of a Branch
VIII. Taxation of Partnerships
IX. Taxation of Other Business Entities
X. Taxation of Individuals
XI. Taxation of Nonresident Individuals
XII. Capital Acquisitions Tax
XIII. Intercompany Pricing
XIV. Multinational Corporations — Special Provisions Relating Thereto and Ireland as a Location for the Operations of
XV. Avoidance of Double Taxation
XVI. Anti-Avoidance

Aidan Fahy
John Ryan
Chair, Tax Department
Pat English
Pat English
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