Moving to Ireland from the UK can feel deceptively straightforward. Both countries speak the same language, share strong cultural links and operate progressive tax systems where many terms look familiar, whether it is PAYE, tax credits or capital gains tax.
However, familiar wording doesn’t mean identical rules and caution is needed if mistakes are to be avoided.
Irish tax law differs in subtle but significant ways. At the same time, the UK is also undergoing important tax reform, particularly around inheritance tax, which means planning now (more than ever) requires a cross-border lens.
This guide explains the main Irish tax considerations for British people and highlights key differences that often catch even the most knowledgeable people out.
Disclaimer
This article provides general information only and does not constitute tax or financial advice. Always seek guidance from a qualified specialist with UK and Irish expertise before taking action.
Becoming tax resident in Ireland
Irish tax residence is primarily based on physical presence:
- 183 days in Ireland in a tax year, or
- 280 days over two consecutive tax years, with at least 30 days in each year
Ireland also offers split-year treatment in certain circumstances, but it does not operate in the same way as the UK’s Statutory Residence Test (SRT). The SRT contains multiple ties and detailed criteria. Ireland tax residence status is based mainly on day presence and intention, which can make it deceptively simple and easier to trigger residency unintentionally.
Understanding which year you become Irish resident can affect how your income is taxed, how gains are treated and whether double tax relief applies.
Worldwide taxation and domicile
As with the UK, once you become resident in Ireland, you are generally taxable on worldwide income and gains. Domicile continues to be relevant for certain Irish tax exposures, particularly inheritance and gift tax.
It is possible to live in Ireland while remaining domiciled in the UK. However, UK rules on domicile and UK inheritance tax are themselves changing, which means relying on domicile alone for tax planning is no longer safe.
Typical personal tax requirements in Ireland
Ireland has three main components to personal taxation which it is important to be familiar with:
- Income tax
- Universal Social Charge (USC)
- Pay Related Social Insurance (PRSI)
Combined, these often create a higher effective tax rate for middle to higher earners compared to the UK.
One key difference is that Ireland uses tax credits rather than a personal allowance. Credits reduce tax due rather than income subject to tax. This changes how income planning works, especially where employment, rental or investment income is involved.
Income tax rates in Ireland
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Filing status
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Tax rate at 20% applies to income up to
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Tax rate at 40% applies to income over
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Single / widowed (no dependent children)
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€44,000
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Balance over €44,000
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Married couple (one income)
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€53,000
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Balance over €53,000
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Married couple (two incomes)
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€88,000
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Balance over €88,000
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These are the standard-rate bands. Universal Social Charge (USC) and PRSI apply in addition to income tax.
Remittance basis in Ireland
Ireland applies a remittance basis of taxation for individuals who are resident but not domiciled in Ireland. This means:
- Irish-source income and gains are always taxable in Ireland
- Foreign income and foreign gains are only taxable if remitted to Ireland
Unlike the old UK system:
- There is no annual remittance basis charge
- You do not elect into the regime, it applies automatically if you are non-domiciled
- There is no time limit on using the remittance basis
- However, there are strict rules around what counts as a remittance and anti-avoidance provisions
Key points for British people moving to and living in Ireland
For British nationals moving to Ireland:
- Many retain a UK domicile for some years, so the remittance system can apply
- If you remit foreign income or gains to Ireland, they generally become taxable
- Keeping investment income abroad and not bringing it into Ireland might defer tax
- Care is needed to avoid unintended remittances (e.g. paying Irish expenses from foreign income accounts)
- Remittance planning must be done before becoming Irish resident
- Mixed funds rules, loans, and indirect remittances all apply
- The regime does not apply once you are considered domiciled in Ireland
Most importantly: holding funds offshore to avoid remitting them can complicate life in Ireland, particularly when financing living expenses or property purchases.
Capital gains tax in Ireland
Ireland charges a flat rate of 33 percent on most capital gains. Unlike the UK, there is no annual exemption, so even modest disposals can trigger a charge.
If you plan to dispose of assets, the timing of your move matters. Selling property, shares or a business interest before or after becoming Irish resident can produce materially different outcomes.
Doing so without planning can also trigger taxation in both countries, even where relief is available.
Remember, if you are tax resident in Ireland and selling a UK asset, you will probably still be required to report and pay Capital Gains Tax in the UK, although you will likely be able to offset any payments through the double tax treaty between the UK and Ireland so you only pay tax once.
Property and rental income
If you keep a property in the UK and rent it out, Ireland can tax that rental income once you become resident. The UK may also tax it, but the double tax treaty allows relief so you do not pay tax twice on the same profit.
Selling UK property once resident in Ireland may create capital gains tax exposure in both countries as well.
Even though the UK rules changed in April 2020 to tax non-residents on UK property gains, the Irish rules may apply too. The sequence and timing of events matter.
Tax on pensions and retirement income
Pensions require careful planning before and after relocation. UK pension income is generally taxable in Ireland for Irish residents, governed by the UK Ireland double tax treaty.
Key points to be aware of:
- Pensions that are tax efficient in the UK may not be treated the same in Ireland
- Drawdown timing can affect how much tax is payable
- Transfers need careful advice to avoid unexpected tax charges
With the UK removing the lifetime allowance, but Ireland applying different pension rules and tax structures, the right strategy depends on your long-term plans.
Inheritance, gift tax and the UK shift away from domicile
Ireland taxes inheritances and gifts under Capital Acquisitions Tax, generally at 33 percent above set thresholds. Liability can arise based on your residence or domicile, the residence or domicile of the person giving the gift or inheritance and the location of the assets.
Historically, British people have assumed that moving to Ireland while keeping a UK domicile meant their worldwide estate would remain under the UK domicile-based inheritance tax regime.
This assumption is no longer reliable.
From April 2025, the UK is moving away from a domicile-based system for inheritance tax. Instead, exposure to UK IHT will depend primarily on residence. Key changes include:
- Long-term residence rules, generally based on being UK resident for ten of the previous twenty tax years
- A tail period, meaning leaving the UK does not immediately end worldwide IHT exposure
- Traditional domicile-based planning may no longer provide the same protection
For British people living in Ireland, this means you may remain within scope of UK IHT on worldwide assets for years after leaving, depending on your UK residence history. Combined with Irish inheritance tax rules, careful estate planning is essential.
Investments, ISAs and tax-efficient planning
ISAs are not recognised in Ireland, so returns can become taxable when you become Irish resident. UK investment structures, offshore policies and certain funds may also receive different treatment in Ireland.
Reviewing investments before relocating can help prevent holding assets that lose their tax advantages once you arrive.
Why specialist, cross border tax advice matters
Cross-border tax planning between Ireland and the UK has become more complex. Relying on familiar-sounding terminology or assuming systems work the same way can lead to unnecessary tax, double taxation or missed planning opportunities.
Professional advice is particularly important if you:
- Hold property in the UK
- Have pensions or investments in the UK
- Expect to receive gifts or inheritances
- Have business interests in either country
- Plan to sell assets before or after moving
Early planning helps avoid expensive surprises and ensures you structure your affairs efficiently from day one.
Checklist of tax matters to cover when moving from the UK to Ireland
Before leaving the UK
Before you leave the UK, the following actions should be undertaken and you should speak to a specialist to avoid making any costly mistakes.
Notify HMRC
- Complete form P85
- Ensure employer issues P45
- Retain P45, P60 and payslips
Confirm UK residence position
- Review statutory residence test
- Check split-year eligibility
Final UK tax return
- Determine if Self-Assessment is required
- Plan timing of bonuses, share schemes and dividends
Review UK tax wrappers
- ISAs lose tax benefits once resident in Ireland, work out what your most tax efficient options are in the short and long term
Consider disposals
- Review gains on shares, funds or property before leaving
Pensions
- Review drawdown and tax strategy
- Consider benefits timing
After arriving in Ireland
Register for Irish tax
- Obtain PPS number
- Register with Revenue if required
Understand Irish residency rules
- Track days to avoid dual residence issues
Tax on income
- Review Irish treatment of employment, rental and investment income
UK assets
- Understand Irish treatment of ISAs and UK funds
Record keeping
- Maintain proof of arrival, income and taxes paid
Continuing UK responsibilities
UK property
- File UK tax returns for rental income
- Register for Non Resident Landlord Scheme
- Report UK property gains if selling or disposing of a UK property
UK based income
- UK may still tax certain income
- Claim double tax relief where appropriate
Investments
- Maintain reporting for UK assets
Frequently asked questions
How does Irish tax residency work?
You are typically Irish tax resident if you spend 183 days in Ireland in a tax year, or 280 days across two years. Split-year treatment may apply but it operates differently to the UK rules.
Will I pay tax on my UK rental income in Ireland?
Yes. Ireland taxes worldwide income for residents. You can usually claim credit for UK tax paid under the double tax treaty.
Are UK ISAs tax-free in Ireland?
No. ISAs lose their UK tax advantages once you become resident in Ireland, and returns may be taxable.
How are pensions taxed when I move to Ireland?
UK pension income is usually taxable in Ireland for residents, subject to treaty rules. The right drawdown strategy depends on your circumstances.
How do the new UK inheritance tax rules affect me?
From April 2025, UK IHT will be based on long-term residence rather than domicile. British people moving to Ireland may remain within UK IHT scope for years after leaving.
When to get cross border tax and financial advice
Seek professional cross-border advice if you:
- Hold UK property or investments
- Expect pension withdrawals
- Own a business
- Plan asset disposals
- Expect significant inheritance or gifting
If you are planning to move to Ireland and want clarity around tax, investments or pensions, we can introduce you to a trusted tax specialist who understands both the UK and Irish systems. They will help you understand your options and structure your finances in a tax-efficient way.
