A company is resident where it is centrally managed and controlled.
A non-resident company is chargeable to corporation tax on:
- Income arising through an ROI-located branch or agency (s 25).
- Chargeable gains derived from land, mineral rights, or assets used for the branch or agency.
An Irish registered company is automatically treated as ROI resident for tax purposes (s 23A). This rule does not apply in the case of a company:
- that is ultimately controlled by persons resident in an EU State or tax treaty country, or
- regarded as non-resident under the terms of an Irish tax treaty.