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.