We would like to point out that the tax concepts and calculations shown on this website are only examples and illustrative; they are also not complete in some cases. DUNAMIS MIND accepts no liability and gives no guarantee that they are up-to-date, complete and correct.
Binding advice is given by us exclusively in personal contact on the basis of a corresponding order agreement.
No rules on Controlled Foreign Corporation (CFC) taxation in Ireland
In Ireland, unlike Germany, there are currently no rules on Controlled Foreign Corporation taxation. It is planned to introduce such rules from 01.01.2019; at present it looks as if the rules will continue to allow for reasonable usage actions.
CFC rules is the taxation of income of a foreign subsidiary by the domestic shareholder.
It is intended to prevent unlimited taxpayers from transferring their foreign income to a taxable company that has its registered office in a low-tax country and is not taxable in Germany, thereby obtaining tax advantages. The income (interim income) of foreign companies (intermediate company) is added to the income of unlimited taxpayers in proportion to their participation (additional amount). The additional amount is added as capital income within the scope of a so-called distribution fiction.
In Germany the CFC rules are sections 7 – 14 AStG (Foreign Tax Act).
Other countries without CFC rules include Belgium. Gibraltar, Hong Kong, Croatia, Luxembourg, Malta, Romania, Switzerland, Slovakia, Czech Republic, Cyprus.
Due to the lack of CFC rules, Ireland is a suitable location for a holding company with an offshore subsidiary.
Ireland has rules regarding a tax Non-Dom status, see our International section.