Irelandの税務居住ルール：183日テスト
183日のしきい値
Irelandにおける183日ルールの仕組み
Ireland applies a 183 day test per tax year, or 280 days over two consecutive tax years.
暦年（1月〜12月）. これは、日数カウントが毎年1月1日にリセットされることを意味します。前年の日数は繰り越されません。
183日を超えると、Irelandは税務居住者としてあなたの全世界所得に課税する可能性があります。具体的な影響は、個人の状況、適用される租税条約、所得の種類によって異なります。
日数のカウント方法
Ireland runs two day count tests. The first is the headline 183 days in a single tax year, which lines up with the calendar year now. The second is sneakier: spend 280 days or more in Ireland across two consecutive tax years, with at least 31 days in each, and you are treated as resident in both years rather than neither.
1日とみなされる条件
Any day you set foot in Ireland counts, arrival and departure days included. Until 2009 the rule looked at where you were at midnight, but Revenue switched to a present in state test, so even short same day visits now go on the count.
日数以外の判定基準
Beyond plain residency, Ireland layers on a status called ordinary residence. After three consecutive years as an Irish resident, you become ordinarily resident, and that status follows you for three further years after you leave the country, with effects on the taxation of certain foreign income. Sitting above it is domicile, a deeper common law concept that determines how foreign income is taxed for Irish residents on the remittance basis.
特別税制
The remittance basis is the regime worth knowing. Non domiciled Irish residents pay Irish tax on foreign source income and gains only when those amounts are actually brought into Ireland. For inbound employees, the Special Assignee Relief Programme (SARP) goes further and grants a 30% deduction on employment income above a threshold.
租税条約
Ireland has a wide treaty network and applies the standard OECD tiebreaker. Treaties can also reduce withholding on dividends, interest, and royalties coming into Ireland from another treaty country.
よくある質問
How does the 280 day rule work?
It is the rule that catches people who try to split their time evenly across two tax years to avoid hitting 183 days in either one. Spend 280 days or more across two consecutive years with at least 31 days in each, and Ireland treats you as resident for both years rather than neither.
What is the difference between residence and domicile?
Residence asks where you spend the year. Domicile asks where you consider your permanent home, in the common law sense. As a non domiciled Irish resident, you pay Irish tax on foreign income only when it is remitted to Ireland.
When does ordinary residence apply?
It kicks in once you have been Irish resident for three years in a row, and it sticks for three further years after you leave. While you are ordinarily resident, certain types of non Irish income remain inside the Irish tax base, even though you no longer live in Ireland.
公式情報源: https://www.revenue.ie/en/jobs-and-pensions/tax-residence/index.aspx