What the UK still does for tax when you move to Ireland

Most accounts of a move to Ireland stop just where it gets interesting. They explain non-dom status, the remittance basis and the corporation tax rate, and they say nothing about the question that for a family with wealth is the more expensive one: what does the country you are leaving do?

For the UK the answer has four parts, and none of them is an exit tax. The UK does not treat your departure as a sale of your shares; what it has instead is a five-year rule that brings gains made abroad back into UK tax if you return too soon. Inheritance tax follows long-term residence and keeps your worldwide assets in scope for three to ten tax years after you leave. A workplace pension from the UK is taxed, under the convention, in the country where you live, while a pension for government service stays with the state that pays it; the details are on the page on pensions in Ireland. And the tax year of the move can be split, but only on conditions that a house kept in the UK can defeat.

The convention itself has a page of its own, because its numbering is its own. Residence is in Article 4, the clause that limits relief to what you bring into Ireland is Article 6, near the front, gains are in Article 14 and pensions in Article 17. Anyone who borrows the numbers of another treaty quotes the wrong provision. For inheritance tax, the UK and Ireland have a second convention, and that is rarer than it sounds: Ireland has one with only two countries.

That is why these pages never make a statement about the UK in general where Scotland, a company or a pension is treated differently. Where we have no reliable answer for a case, the gap stays on the page, not an average that does not exist.

Every statement here is checked against the legal text: the convention in HMRC’s synthesised text, UK statute on legislation.gov.uk, HMRC’s manuals and guidance, and the instructions of the Irish tax administration. Every figure carries its source and its date. Where a statement rests on a reading and not on published guidance, we say so instead of making it sound firmer than it is.

The Irish side of the same move is in the section Tax: non-dom and the remittance basis, the order of your accounts before you arrive, the year of arrival, funds and ETFs, the Irish company and the 33 per cent on inheritances. Putting the Irish side into practice, registering with Revenue and the first Irish return, we take on as the tax registration as a non-dom.