Taxes Consolidation Act 1997 section 127B

Tax treatment of flight crew in international traffic

Section 127B charges income tax under Schedule E on the employment income of flight crew members who work aboard aircraft operated in international traffic by an enterprise with its place of effective management in Ireland, while providing an exemption from 2022 for non-resident crew members who satisfy certain conditions.

• Flight crew members working on aircraft in international traffic operated by an Irish-managed enterprise are chargeable to income tax under Schedule E and within the PAYE system, regardless of whether they are resident in Ireland.
• From the 2022 tax year onwards, non-resident flight crew are exempt from this charge if they are resident in a country with which Ireland has a double taxation agreement (DTA) and are subject to tax on the income in a DTA territory.
• "International traffic" does not include flights operated solely between places within another single country (i.e. foreign domestic flights are excluded).
• Where the exemption does not apply, relief from double taxation may still be available under the terms of the relevant DTA between Ireland and the crew member's country of residence.