Has anyone here contracted in Ireland via their UK ltd company?
I have the possibility of a contract in Dublin. The contract should allow me to work remotely at least a couple of days a week. If I'm not going to be in Ireland for more than 183 days in their tax year, or 280 days across 2 tax years, am I right in thinking that I will have no liability for any Irish tax personally and for my company?
The relevant articles in the double taxation treaty between Ireland and the UK would seem to be the following:
Based on my reading of those clauses, providing I keep myself under 183 days a year/280 over 2 years, I can just invoice the Irish client from my UK company. Or am I missing something?
Hopefully this is the case - 9 months on the bench and I'm starting to get pretty bored!!
I have the possibility of a contract in Dublin. The contract should allow me to work remotely at least a couple of days a week. If I'm not going to be in Ireland for more than 183 days in their tax year, or 280 days across 2 tax years, am I right in thinking that I will have no liability for any Irish tax personally and for my company?
The relevant articles in the double taxation treaty between Ireland and the UK would seem to be the following:
Article 15
Employments
1. Subject to the provisions of Article 17 and 18, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph (1) of this Article, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the fiscal year concerned; and
b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; and
c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. In relation to remuneration of a director of a company derived from the company the preceding provisions of this Article shall apply as if the remuneration were remuneration of an employee in respect of an employment and as if references to "employer" were references to the company.
Employments
1. Subject to the provisions of Article 17 and 18, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph (1) of this Article, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the fiscal year concerned; and
b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; and
c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. In relation to remuneration of a director of a company derived from the company the preceding provisions of this Article shall apply as if the remuneration were remuneration of an employee in respect of an employment and as if references to "employer" were references to the company.
Article 8
Business Profits
1. The profits of an enterprise of a Contracting State shall be taxable only in that State unless the enterprise carried on business in the other Contracting State through a permanent establishment situated therein. If the enterprise carries on business as aforesaid, the profits of the enterprise may be taxes in the other State but only so much of them as is attributable to that permanent establishment.
Business Profits
1. The profits of an enterprise of a Contracting State shall be taxable only in that State unless the enterprise carried on business in the other Contracting State through a permanent establishment situated therein. If the enterprise carries on business as aforesaid, the profits of the enterprise may be taxes in the other State but only so much of them as is attributable to that permanent establishment.
Hopefully this is the case - 9 months on the bench and I'm starting to get pretty bored!!
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