UK & Ireland remittance basis

Ireland taxes a resident, but non domiciled, individual's income on a remittance basis except where the income has a UK source; when the arising basis applies. The UK similarly taxes a resident, but not domiciled, individual's income on a remittance except where the income has an Irish source.

The European Commission has held that the Irish basis of taxation for UK source income is discriminatory and restricts the free movement of capital contrary to Art 56 EC. Ireland has been formally asked to amend its legislation in order to remove the anomalous treatment of UK source income. Enquiries have been made of the UK, with the likelihood being that the Commission will also proceed in asking the UK to amend its equivalent legislation (section 831(5) ITTOIA).