French dividends paid to a French citizen living in Ireland

D

deadlyduck

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I'm asking this on behalf of a friend:

She is French born, married to an Irish citizen and living in ROI for past 14 years.
Her family business has paid her dividends which were taxed in France and the net amounts remitted to Ireland.
Am I correct in thinking the following:
1. As they were remitted to Ireland, Irish tax is payable on the gross French dividend.
2. A credit is available for the French tax deducted.
3. [The issue I'm not sure at all about] If she hadn't remitted the dividends to Ireland, no Irish tax would be payable due to her non-domicile status?!

All help greatly appreciated.
 
If she's ordinarily resident in Ireland she's liable to tax on dividends (or any other income) earned anywhere in the world — regardless of whether this is remitted to Ireland. But she will get a credit for the taxes deducted in France. In fact, I suspect the French tax may be higher than what she would have been liable for in Ireland, so it may be that there is no further tax payable. But she should declare it anyway.
 
two points

As long as your friend is not Irish domiciled she would only be taxed on the dividends as remitted to Ireland.

Also, the french credit should include credit for the underlying French corporation tax suffered on the dividends as allowed for in the Ireland france double tax Treaty

[broken link removed]
 
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