PBR – remittance basis for Irish income

UK resident individuals, who are not also ordinarily resident, or not domiciled within the UK, can benefit from the remittance basis for foreign earnings or foreign investment income. Income arising in Ireland has, however, been treated as UK income for these purposes. From 6 April 2008, it is proposed that the remittance basis be extended to income arising in Ireland also. (Irish source capital gains have never been subject to an equivalent restriction.)

This change is inspired by Ireland being pulled up by the European Commission, in March 2007, and told to amend its own, equivalent rules on the ground that they contravene Article 56 which concerns the free movement of capital.