The most important tax planning for Ireland happens before the move.
Existing capital and later income should be cleanly separated before you arrive in Ireland for tax. After the cut-off date, a mixed account history cannot simply be wound back.
The cut-off date
The remittance basis taxes foreign income only when it is brought into Ireland. That raises a question every family moving over asks sooner or later: and the money I already have?
The answer is in Revenue's own guidance, and it is kinder than many expect. Funds that come from income which arose before 1 January of the year in which you become tax resident in Ireland stay free of income tax, even if you transfer them to Ireland later. In advisers' language this money is called clean capital. Keeping it cleanly separate, and being able to show Revenue where it came from, is part of the tax registration we take on for families moving to Ireland.
So the cut-off is not a date you choose but one that follows from your arrival. Everything that arose before it belongs on one side. Everything that arises after it, on the other. The whole art lies in keeping the two sides apart.
A practice, not a statute
A point we put at the start, out of honesty, and not in a footnote: this treatment is a long-standing administrative practice of Revenue, not a statutory rule. In its own guidance Revenue says, in substance, that strictly speaking the income would be taxable, but that for people coming to Ireland for the first time there is a long-standing practice of not taxing it.
A practice like this is solid enough to plan on, and Ireland has applied it for decades. But it is something other than a section of an Act, and it is not written in a statute you could quote. Anyone who sells it to you as a statutory tax exemption has not read the source.
| Item | Content |
|---|---|
| Cut-off date | 1 January of the year in which you become tax resident in Ireland |
| Effect | Funds from foreign income that arose before this date stay free of income tax, even when they are brought into Ireland later. |
| Legal nature | long-standing administrative practice of Revenue, not a statutory rule |
| Order out of mixed accounts | From a mixed account, every transfer counts as a remittance of income until the income in it is used up. |
| Accumulated income | Accumulated income stays income, even after years and even after it has been reinvested. |
Source: Revenue, Tax and Duty Manual Part 05-01-21A "The Remittance Basis of Assessment" (last reviewed May 2026), sections 5.3, 5.4, 5.5 and 5.6. As of: retrieved 24 August 2026.
The order out of a mixed account
The most expensive mistake in this area has a harmless name: the mixed account. If you keep old wealth and new foreign income in the same account, transfers out of it are not taken proportionately but in a fixed order.
From a mixed account, every transfer counts as a remittance of income until the income in it is used up. This rule is not special Irish law but an old rule of tax law in the common law world; Revenue cites the decision in Scottish Provident Institution v Allen, 4 TC 409 for it.
In practice: in an account holding €400,000 of old wealth and €40,000 of new interest, the first €40,000 you transfer to Ireland comes, for tax purposes, out of the interest. Only after that does the old wealth begin. On the bank statement both look identical. For tax they are not.
There is a fine point here that the guidance states expressly and that works in the other direction: if an account also holds employment income that is fully taxable in Ireland anyway, a transfer may be counted as coming from that pot first. What is taxed anyway cannot hurt a second time.
Income stays income
The second rule that surprises families: Accumulated income stays income, even after years and even after it has been reinvested.
If you let foreign interest build up over years, you have not turned it into capital but into accumulated income. If you reinvest that interest in securities and later sell the securities to bring the money to Ireland, for tax you are still remitting the interest. Revenue bases this on case law going back to the 1940s and applies it unchanged.
The converse is the real message of this page. What arose before your cut-off date stays clean, however long it sits and however often it is reinvested. What arises afterwards stays income, however long it sits and however often it is reinvested. What decides is not the route but the time the money arose.
The detour through a loan
A thought almost everyone has at some point: if remitting income is the problem, I take out a loan abroad, bring the loan into Ireland and repay it outside from my income. A loan is not income, after all.
In Ireland this route has been closed since 1971. Section 72 TCA 1997 catches the repayment of foreign loans out of foreign income. The provision dates from a time when exactly this model was common, and it is still in the statute today.
A more recent provision against the detour through a spouse works in a similar way: if you transfer or lend money from foreign income to your spouse abroad so that he or she brings it into Ireland, you have been treated since 2013 as if you had remitted it yourself.
What this means for the move
Three rules lead to one action, and it costs nothing but attention at the right moment.
Before the move you can settle which account carries which money: one for the wealth that arose before your cut-off date, one for everything that comes afterwards. The first pays for your Irish life, the house, the school, the car. The second stays outside. After the move, an account's history can no longer be sorted retrospectively, and nobody can reconstruct it for you.
The second point concerns the cards in your wallet. Paying in Ireland with a card drawn on a foreign account is a remittance under these rules. Which account sits behind which card is therefore not a question of convenience.
And the third: this order is not a scheme and not a structure, but bookkeeping before the move. It has the rare merit that it only works if it is done in time.
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The first step is a conversation
Which money belongs separated before your move is decided once. That is exactly what the consultation is for.