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Generic Tax Name Corporate income tax
Tax name in the national language Corporation tax
Tax name in English Corporation tax
Member State IE-Ireland
Tax in force since 1997/01/01
If abolished, date on which the tax ceases to apply
Business version date 2015/01/01
Version date 2015/02/17
This file was last updated on

Type of tax
Direct taxes Personal income tax
Corporate income tax
Other

Indirect taxes VAT
Excise duty (EU harmonised)
Alcoholic beverages
Energy products and electricity
Manufactured tobacco
Other

Social security contribution Employers
Employees
Other
 
Legal base

Taxes Consolidation Act, 1997 - as amended by later Finance Acts.

 
Who sets
The tax rate is set by




The tax base is set by




The reliefs are set by




Comments
 
Beneficiary





Comments

 
Geographical Scope

Ireland

 
Taxpayers
Domestic-source income of non-resident entities is Taxed
Not Taxed
Comments
 
Tax object and basis of assessment
As general rule, taxable income under corporate income tax includes also








Comments

Income considered Domestic income
Worldwide income (subject to double-tax relief)
Comments

Comments

All profits (including income and chargeable capital gains other than gains from disposals of development land), with the exception of dividends and other distributions received from other resident companies, arising in a company's accounting period are subject to Corporation Tax.

In Finance Bill 2014, the Irish rules of corporate tax residence were amended to provide that all companies that are incorporated in Ireland are automatically tax resident in Ireland (unless otherwise determined under a bilateral tax treaty which supersedes domestic law). The change came into effect for new companies from 1 January 2015 while a transition period will apply until 2020 for existing companies.

Any company, whether tax resident in Ireland or not which carries on a trade in Ireland through a branch or agency is chargeable to Irish corporation tax  broadly speaking, on any income or chargeable gains (other than gains from disposals of development land) attributable to the branch or agency.

 
Deductions, Allowances, Credits, Exemptions
Valuation of inventory
System First-in first-out (FIFO)
Last-in first-out (LIFO)
Average cost
Specific identification (unit method)

Comments

Depreciation rules
 
Buildings
System Straight-line method
Declining balance
Production method
Combination of above
Other
Not-depreciable

Comments
Average depreciation period 25  Years
Average depreciation rate 4.0 %
 
Movable (tangible) assets
System Straight-line method
Declining balance
Production method
Combination of above
Other
Not-depreciable

Comments
Average depreciation period 8  Years
Average depreciation rate 12.5 %
 
Movable fixed assets
System Straight-line method
Declining balance
Production method
Combination of above
Other
Not-depreciable

Comments
Average depreciation period 8  Years
Average depreciation rate 12.5 %
 
Intangible assets
System Straight-line method
Declining balance
Production method
Combination of above
Other
Not-depreciable

Comments

For acquisitions after 7 May 2009.

Average depreciation period
Average depreciation rate 15.0 %
 
Land (if any)
System Straight-line method
Declining balance
Production method
Combination of above
Other
Not-depreciable

Comments
Average depreciation period
Average depreciation rate


Comments

Are there limits to interest deductions? Yes No
If yes:
Definition of deduction limit Wholly and exclusively for business purposes.

Comments

Is there an Allowance for Corporate Equity? Yes No
If yes:
Notional rate applied for allowance

Comments

Losses
Loss carry-forward exists? Yes No
If yes:
Time limit: Indefinite
 
Size limit:
 
Loss carry-backward exists? Yes No
If yes:
Time limit: Indefinite
1  Years  
Size limit:
 

Comments

Subject to certain restrictions, losses may be used by a company against other sources of income, either in its current accounting period, its previous accounting period or future accounting periods.  Certain losses may also be surrendered to a group member.



Comments

Allowance for Corporate Equity:

Interest payments to 75%-nonresident affiliated companies may be treated as distributions of profit and consequently are not deductible.

Deductions/Allowances/Credits:

Any expenses incurred wholly and exclusively for the purpose of the business may be deducted.

Capital allowances are available in lieu of depreciation of certain assets (for example, certain industrial buildings and items of plant and machinery). There are accelerated capital allowances for energy efficient equipment which allow the full amount of depreciation to be claimed in year 1 instead of spread out over 8 years. 

A tax credit of 25% of qualifying Research and Development (‘R&D’) expenditure is available which includes capital expenditure on buildings/structures used for purposes of carrying on qualifying R&D activities.

Tax relief is given in the form of capital allowances for capital expenditure on the acquisition of specified intangible assets for the purposes of trade.

 

Exemptions:

A start-up company that commences a new trade may be exempted from corporation tax for the first three years of trading in respect of the profits and chargeable gains related to that new trade.  This relief is targeted at small start-ups and is subject to limits on the total amount of relief given, with a link to employment created by such companies.

Credit Unions and certain State-controlled bodies are exempt on all of their profits. Charitable companies promoting amateur or athletic games or sports, friendly societies, trade unions, approved superannuation funds and mutual trading companies are all exempt from corporation tax on income, which fulfils certain statutory requirements. Profits from stallion fees to 31 July 2008, stud greyhounds and certain woodlands are exempt. Certain grants to industrial undertakings and certain employment grants are also exempt.

 

Reliefs:

Relief for increases in stock values is available in respect of the trade of farming. The relief consists broadly of allowing a deduction in computing trading profits of 25% (or 100% in the case of certain young farmers who have undertaken designated training and in the case of restocking using compensation payments from disease eradication schemes).

 
Rate(s) Structure
Nominal corporate income tax rate Rate: 12.50 %

Central government surcharge Rate:
Regional government surcharge Rate:
Local government surcharge Rate:
Combined rate (all-in rate) Rate: 12.50 %


Comments

A 12.5% rate applies to trading income and certain foreign dividends.  A rate of 25% applies to non-trading income, gains and profits from mining, petroleum and certain land dealing activities.  A rate of 33% applies to chargeable capital gains.


Special tax rate for SMEs
Special tax rates apply to SMEs: Yes No
If yes:
Nominal corporate income tax rate Rate:
Central government surcharge Rate:
Regional government surcharge Rate:
Local government surcharge Rate:
Combined rate (all-in rate) Rate:


Comments
 
International aspects
Treaty countries Non-treaty countries
 
Repatriated profits are taxed according to the following system Exemption system Exemption system
Tax credit Tax credit
Deduction Deduction
 
Interest received is taxed Yes No Yes No
Tax rate on interest received 25.00 % 25.00 %
Outgoing dividends withholding tax 20.00 % 20.00 %
Outgoing interest payments withholding tax 20.00 % 20.00 %
 
Foreign losses can be set-off Yes No Yes No
If yes:
Minimum direct or indirect shareholding to qualify loss-offset (if applicable) 75.00 %
 
Loss carry-forward exists? Yes No Yes No
If yes:
Time limit: Indefinite
 
Indefinite
 
Size limit:
 
Loss carry-backward exists? Yes No Yes No
If yes:
Time limit: Indefinite
1  Years  
Indefinite
1  Years  
Size limit:
 
Controlled foreign company (CFC-)rules exist? Yes No Yes No
If yes:
Time limit: Indefinite
 
Indefinite
 
Size limit:
 
Threshold for capital or voting power held directly or indirectly by resident in non-resident company
CFC-rules apply if foreign tax rate is lower than
CFC-rules apply for passive income only? Yes No Yes No

Comments   Treaty countries

Foreign Losses: 

Where a foreign branch of an Irish registered company pays tax on its (foreign) profits, the tax paid is allowed firstly as a credit against the Irish tax due on the Irish measure of this profit (i.e. at 12.5%). Any surplus tax not allowed as a credit is allowed as a deduction (i.e. treated as a cost).

Allowed for EU and EEA countries with whom Ireland has a double taxation agreement.  Also allowed for Irish resident companies that are 75% subsidiaries of a) companies resident in treaty partner countries or b) companies quoted on a recognised stock exchange

Loss carry-forward:  The time limit is indefinite and the size limit is not applicable.

Loss carry-backward:  The time limit is 1 years and the size limit is not applicable.


Comments   Non-treaty countries
 
Measures against profit shifting
 
Do Thin Capitalization (TC) rules exist? Yes No
If yes:
Date of first introduction
Introduced as Explicit TC law
Part of CIT law
Test for TC Ratio
Arm's length
If ratio
Value of numerical ratio:
Definition numerator
Definition denominator
 
Debt considered for test Internal
Internal and external
TC depends on shareholding? Yes No
Substantial shareholding threshold
 
Type of shareholding Direct
Indirect
Automatic remedy Yes No
Remedy Non-deductibility of interest
Reclassification as dividend
 
Rules apply to All companies
Foreign companies
Non-EU companies
Transfer pricing rules exists? Yes No
If yes:
Arm’s length principle applied? Yes No
 
Remedy Fee
Tax base increase
 
Tax due date

For accounting periods arising on or after the 1 January 2006 an amount equal to at least 90% of the corporation tax payable for the accounting period must be paid one month before the end of the accounting period.

For accounting periods arising on or after the 14 October 2008, for large companies with a tax liability of more than €200,000 in their previous accounting period, this payment of preliminary tax must be made in two instalments. The first being payable in the 6th month of the accounting period, and the second in the 11th month.  Small companies continue to follow earlier rules.

 
Tax collector

Annual assessment of profits arising in a company's accounting period.

 

The tax return for the accounting period must be filed nine months after the end of the accounting period, at which time the balance of tax due in respect of the accounting period must be paid ("Pay and File").

 
Special features

A surcharge of 20% is payable on the total undistributed investment and rental income of a close company (broadly a company under the control of not more than five persons or under the control of the directors).  Close service companies (companies which provide professional services or engages in certain other types of activities) are also liable to a surcharge of 15% of one half of their undistributed trading income.

In the case of a group of companies the losses of a one group member may be set off against the profits of another group member.

 
Economic function







Comments
 
Environmental taxes



Comments
 
Tax revenue
ESA95 code d51oa (d51ba)

Year
Annual tax revenue (millions)
Currency
Tax revenue as % of GDP
Tax revenue as % of total tax revenue
2012 3,964.00 EUR 2.27
2011 3,751.00 EUR 2.16
2010 3,943.60 EUR 2.37
2009 3,889.50 EUR 2.30
2008 5,071.50 EUR 2.70
2007 6,393.40 EUR 3.24
2006 6,685.00 EUR 3.62
2005 5,503.20 EUR 3.24
2004 5,335.00 EUR 3.42
2003 5,155.50 EUR 3.54
2002 4,803.70 EUR 3.53
2001 4,143.90 EUR 3.40
2000 3,885.27 EUR 3.59

Comments