A company is resident where it is centrally managed and controlled.
A non-resident company is chargeable to corporation tax on:
- any income arising through an ROI-located branch or agency (s 25),
- any chargeable gains derived from land, mineral rights, or assets used for the branch or agency.
A Irish registered company is automatically treated as ROI resident for tax purposes (s 23A). This rule does not apply in the case of a company:
- that is ultimately controlled by persons resident in another EU State or tax treaty country, or
- regarded as non-resident under the terms of an Irish tax treaty.