OH Tax Residency & Taxable Income 2011

Nutso

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Hi All,

Just looking for some clarification regarding my OH's tax residency.

Background is that he was out of the country for over 183 days in 2011 in a country that does not have a double taxation agreement with Ireland. Prior to that he was resident in Ireland.

I have been in touch with a tax accountant who has said that as he was resident in Ireland for the 3 years prior to 2011, his worldwide income is taxable in Ireland for 2011.

I found the following on the Revenue website (http://www.revenue.ie/en/tax/it/leaflets/res1.html#section1):


What is "Ordinary Residence"?
The term ordinary residence refers to an individual’s pattern of residence over a number of tax years. If you have been resident in the State for three consecutive tax years, you are regarded as ordinarily resident from the beginning of the fourth tax year. Conversely, you will cease to be ordinarily resident in the State having been non-resident for three consecutive tax years. A person can be non-resident for a tax year but still be ordinarily resident for that year if the absence is temporary.

Non-resident individuals
Individual who is non-resident but is ordinarily resident in the State for the tax year in respect of which tax liability is to be calculated
Such an individual is, for that tax year –
a. treated in the same way as an individual who is tax resident (see Tax Resident Individuals above); but
b. will not be taxable on -
i. the income derived from a trade or profession no part of which is carried on in the State;

ii. the income derived from a non-public office or a non-public employment all of the duties (except incidental duties) of which are performed outside the State (but see Non-resident directors of Irish incorporated companies below re Irish public offices);
iii. other foreign income (e.g. investment income) which, in the tax year, does not exceed €3,810.

Note part in bold - this would suggest to me that his income is not taxable as his trade profession was not carried on within the state? Am I reading this correctly or am I missing something that means his worldwide income is taxable?

Thanks,
Nutso
 
There's also the 2 year rule to consider.

If he was in Ireland for more than 30 days in 2011, and the total number of days he was in Ireland in 2010 and 2011 combined exceeds 280, then he would be tax resident in Ireland for 2011. He'd therefore be taxable in Ireland in 2011 on his worldwide income.

If he is an employee and is non-resident in 2012 he may be able to avail of split-year residence relief. He would then be taxed on his employment income in Ireland up to the date he left and deemed to be non-resident after that date.
 
Thanks for the info Smeharg.

The total no of days in Ireland in 2010 and 2011 exceed 240, however he has already been out of Ireland for greater than 183 days in 2012. He was on JB for the first couple of months of 2011 and then JA for a couple of months in 2011.

Would split year residence relief apply in this case?
 
If the total days spent in Ireland in 2011 and 2012 is 280 or more he'll be tax resident in 2012 also.

If he's non-resident in 2012 split-year residence relief should be available if he is employed and not self-employed. You highlighted the reference to self-employed (ie trade or profession) in your initial post which led me to believe he was self-employed and not an employee.
 
Actually I am not entirely sure if he was employed or self employed in his first position. At the moment he is definitely an employee but this is his second employment in the country in question and the previous company (with no Irish ties) are not responding to requests for information.

Is it 280 days between the two years rather than 240 which would confirm tax residency for 2012?

Thanks again for the response.
 
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