I've had job offers over the years from the Caymans and the Channel Islands. Both of which have no CGT, and 0, 20% income tax rates respectively. If I was going to move though, I would set up on my own. Both jurisdictions have attractive start-up policies and resources not to mention location.
A mid-year move from Ireland.
So resident, ordinarily resident, and domiciled for the first year.
Non-resident, ordinarily resident, and domiciled after that.
Tax implications for the first two years.
Ignore Double Tax.
It's a software company that I will control. A close company.
No matter what title I give myself, by the definition I posted, I am classified as a director.
My current understanding:
For three years, I will be treated as If I never left Ireland. Ignore DTT.
Split-year tax treatment is out, as I am classified as a director(many websites seem to leave out this caveat.)
All my income, non of which is earned in Ireland, will be subject to Irish income tax.
CGT on company capital sales is less clear. I believe, as the asset was created outside of Ireland by the company, and it's software rights, I will not have to pay CGT. But if, as I'm a director, the point is academic as when it runs through the company to me, as either a salary/bonus payment or dividend, I am liable for the full thing.