Corporate Tax

Irelandoffers a stable and attractive corporate tax environment for businesses in Ireland. Key tax rates applicable to businesses in Ireland are provided in this section.

 

Corporation tax rates

Corporation tax rates

Trading income (including qualifying foreign dividends paid out of trading profits)

12.5%

All other income (including non qualifying foreign dividends)

25%

Deposit interest retention tax (DIRT)

27%

Dividends from Irish resident companies

Exempt

 

Foreign tax suffered on foreign dividends received (underlying and withholding tax) can be credited against Irish tax payable on such dividends and any excess foreign tax credits may be pooled for offset against Irish tax payable on other foreign dividends. Separate pools are maintained for trading and non trading foreign tax credits as trading credits cannot be used to offset tax payable on a non qualifying foreign dividend.

Trading losses

Trading losses can be used as follows:

  • Offset trading income and foreign dividends taxable at the 12.5% rate in the same period
  • Offset trading income of the immediately preceding period
  • Offset trading income of subsequent periods

To the extent not usable against trading income, a trading loss can be converted into a tax credit which may be used to reduce the corporation tax payable on other passive income and chargeable gains.

 

R&D tax credits

  • 25% tax credit available for incremental R&D expenditure over 2003 base year expenditure
  • Available for spend on qualifying R&D buildings
  • Repayment of excess credits available over three year period
  • Ability to account for R&D tax credit above or below the line

 

Capital gains tax

Capital gains tax

Chargeable gains

25%

Gains from disposals of qualifying subsidiaries

Exempt

 

Losses are set off against chargeable gains arising in the same year. Unused losses may be carried forward indefinitely.

 

Start-up companies

New or start-up companies, which were incorporated on or after 14 October 2008 and which commence trading between 2009-2011 are, subject to certain conditions, exempt from corporation tax on the income and chargeable gains arising from the trade and trading assets. This relief applies for three years from the commencement of the trade.

 

Closely held company surcharge rates

Closely held company surcharge rates

Surcharge payable on the total undistributed investment and rental income

20%

Additional surcharge payable by service company on one-half of undistributed income

15%

 

 

Dividend withholding tax

A withholding tax at the standard income tax rate (20%) applies to dividends and other profit distributions of an Irish tax resident company other than when made to its 51% Irish tax resident parent company. Wide ranging exemptions from withholding tax are available for shareholders in particular circumstances.

 

Capital allowances

Asset

Allowance

Plant & machinery

Annual allowance of 12.5%

Computer software packages
(for expenditure incurred before 4 February 2012)

Annual allowance of 12.5%

Motor vehicles – maximum cost allowed is €24,000
(reduced for high CO2 emission cars)

Annual allowance of 12.5%

Industrial buildings
(located in Ireland)

Annual allowance of 4%
(unless qualifying for accelerated capital allowances)

Intangible assets

Annual allowance equal to depreciation/amortisation charged to accounts or alternatively option to elect for annual allowance of 7% for 14 years and 2% in year 15

Patent rights
(by election for expenditure incurred before 
Saturday, 7 May 2011)

Annual allowance over shorter of 17 years or life of patent

Industrial know-how
(by election for expenditure incurred before 
Saturday, 7 May 2011)

Once off allowance of 100%

Energy efficient plant & machinery

Once off allowance of 100%

Scientific research

Once off allowance of 100%