AITI Chartered Tax Adviser

How are foreign companies trading in Ireland charged for corporation tax?

If your company is not resident in Ireland, it is not chargeable to Irish corporation tax unless it trades through a branch or agency in Ireland. If it so trades, it is liable to corporation tax on:

(a) any income arising through the Irish branch, and

(b) any chargeable gains made by selling land or assets used by the Irish branch.

A foreign company with a presence in Ireland is not liable to Irish corporation tax unless the Irish branch or agency constitutes a permanent establishment. If its presence is only an office or showroom which passes on orders to head office in the home country, and goods are dispatched from the home country, it is not a permanent establishment. If, however, there is a manager or agent in Ireland who has power to conclude contracts on behalf of the company, that manager or agent can constitute a permanent establishment.