Taxes Consolidation Act 1997 section 822

Split year residence

Section 822 provides for split year treatment, a residence deeming measure that allows qualifying employees who arrive in or depart Ireland during a tax year to be treated as resident only for part of that year for the purposes of charging employment income to tax.

• Split year treatment (SYT) applies only to income from an employment — it does not extend to other forms of income such as directorship income or investment income — and it splits the year of arrival or departure into a period of deemed residence and a period of deemed non-residence, with only the employment income arising in the deemed-resident period being chargeable to Irish tax.
• Under the Finance Act 1994 scheme, the individual must satisfy an authorised officer during the year of arrival or departure that the relevant residence conditions will be met; if this in-year requirement is not met, SYT is not available and the individual's full annual employment income is chargeable to Irish tax, subject to any double taxation agreement relief.
• The Finance Act 2024 amendment introduced an alternative self-assessment route, effective for arrivals and departures from 1 January 2025, allowing individuals to claim SYT in their income tax return for the year of arrival or departure without needing to satisfy an authorised officer during that year.
• Qualifying individuals are entitled to full annual tax credits and standard rate bands for the year of arrival or departure, even though they are only chargeable on employment income referable to the deemed-resident part of the year, and the pre-arrival or post-departure employment income is excluded from the income tax return.