As announced in December 2009, an annual domicile levy will come into effect from 1 January 2010.
This levy applies to individuals who are Irish domiciled and are citizens of Ireland and who have:
- Worldwide income exceeding €1,000,000
- An Irish income tax liability of less than €200,000, and
- Irish property with a valuation in excess of €5,000,000 as at 31st December in the relevant year. In estimating the value of the asset, no deduction is allowed for debts or encumbrances.
Irish property is broadly defined for the purposes of this section to cover rights and interests of every description.
Assets that are specifically excluded from the definition of Irish property are shares in a company which exists wholly or mainly to carry out a trade or a holding company that derives most of its value from trading subsidiaries.
Shares in foreign corporate entities may also come within the definition of Irish property if the shares derive the greater part of their value from Irish situated assets, namely land or buildings in the State.
An individual subject to this levy will be entitled to a credit against this levy for Irish income tax already paid in Ireland in the relevant year.
The levy applies irrespective of the individual’s tax residence status and it will be payable on a self assessment basis.
At BDO we have a team of professionals who will analyse your position regarding the domicile levy.