Irish Registered Non-Resident Companies and the ‘Double-Irish’

Irish Registered Non-Resident Companies and the ‘Double-Irish’

An Irish registered non-resident (IRNR) company is one which is incorporated in Ireland but is not resident here for tax purposes. This is because the company is controlled and managed from abroad. These companies pay tax on Irish sourced income only and can be used for International tax purposes.

An Irish company is deemed to be resident in Ireland for tax if It is managed and controlled in Ireland. Irish resident companies are taxed on worldwide income. Relief is provided in the form of credit for tax paid in countries with which Ireland has a double taxation treaty.

For US businesses, the ‘Double-Irish’ depends on the ’same-country’ exemption that facilitates deferral of US corporation tax until dividends are paid there. Transfer of Income between two Irish companies would not trigger payment of corporation tax in the US. A US company could have a Subsidiary in Ireland and an Irish Holding Company. The Subsidiary ‘Company A’ could make patent royalty payments to the Holding Company. The Holding Company would be Non Resident if it is controlled from outside Ireland, typically in a low tax jurisdiction. Both companies, as they are Irish incorporated, would be deemed to be Irish Resident by the US tax authorities, ie:;same-country’