Thinking about moving to Ireland from the US but wondering how your US assets will fit into the picture? Or maybe you’re curious about inheritance rules and estate planning across the pond?
When planning your big move, it can be hard to sort through all the information out there and whittle down what actually applies to you.
But you’re not in it alone. This guide is your roadmap for managing foreign assets, understanding inheritance taxes, and organising your finances when moving to Ireland.
Handling Foreign Assets When Moving to Ireland
The biggest question ahead of your move is how your foreign assets – like property, investments, bank accounts – are treated under Irish tax law.
How Irish Tax Law Treats Foreign Assets
Unlike in the US, where you’re taxed based on your citizenship, Ireland taxes individuals based on their residency, ordinary residency and domicile.
Residency
If you’re resident in Ireland but not domiciled here (often called a non-dom), you’re only taxed on:
- Income and gains earned in Ireland; and
- Foreign income or gains that you bring into Ireland, known as the remittance basis
Under the remittance basis, your foreign income and capital gains are only taxed if you transfer (remit) them to Ireland. Anything you earn and keep abroad generally remains outside the Irish tax net. (N.B. Caution is required if using the remittance basis to ensure you do not inadvertently remit income or gains to Ireland e.g. by using a foreign credit to pay for day-to-day expenses in Ireland.)
How to Determine If You’re an Irish Resident for Tax Purposes
You’re considered tax-resident in Ireland if you spend:
- 183 days or more in Ireland in a single tax year, or
- 280 days or more over two consecutive years (as long as you’re in Ireland at least 30 days each year).
If you spend less time than that, you’re generally considered non-resident for tax purposes.
What Is Split-Year Treatment?
If you move to (or leave) Ireland part way through the year, you’re usually treated as tax-resident only from the date of arrival (or until departure) on employment income. Employment income earned before (or after) your move is generally not taxed in Ireland.
Domicile
This isn’t about where you’re living but where your permanent home is. Even if you move to Ireland full-time, you might remain US-domiciled if your long-term ties – like family and property – are still in the US, and if you have the intention of returning in the future.
In Ireland, it can be hard to prove a new domicile (a “domicile of choice”) but you can remain non-domiciled as long as you show a real connection to your original country.
If you are a long-term resident in Ireland but non-domiciled (e.g. resident in Ireland for more than 5-7 years) it is recommended you review your domicile position in conjunction with a tax adviser.
How Ireland Taxes Your Foreign Income and Assets
Income Tax
If you’re both resident and domiciled in Ireland, you’re taxed on your worldwide income, including income earned abroad. Irish income tax rates range from 20% to 40%, depending on your income level. Universal social charge and PRSI also apply in most cases, more on that below.
If you’re resident but not domiciled, you only pay income tax on income earned in Ireland, and foreign funds that you bring/remit into Ireland
Universal Social Charge (USC)
This is a separate tax that applies to most types of income – including employment, self-employment, pensions, and rental income earned in Ireland.
It’s calculated on a sliding scale – between 0.5% and 11% – depending on your total income level. Generally speaking:
- Irish residents pay USC on all Irish-source income.
- Non-doms pay USC on the amount of income taxed in Ireland. i.e. If income is not remitted it is not subject to USC in that year.
Pay Related Social Insurance (PRSI)
This tax funds Irish social benefits like pensions and unemployment support.
- Irish residents pay PRSI on income earned in Ireland through the Pay As You Earn (PAYE) system. PRSI (Pay Related Social Insurance) applies to Irish resident individuals based on their income and type of work.
- Non-domiciled residents may have a slightly more complex PRSI situation but broadly speaking pay PRSI on the amount of income taxable Ireland in a given year. Cross-border PRSI analysis can be quite complex!
The US-Ireland Totalization Agreement helps US expats avoid paying social security taxes in both countries.
Capital Gains Tax (CGT)
If you’re an Irish resident, you usually pay Capital Gains Tax (CGT) at 33% on gains from selling assets like property, stocks, or other investments. If you’re Irish-domiciled, this applies to assets worldwide. If you’re non-domiciled, it generally only applies to Irish assets and the amount of gain on foreign assets you remit into Ireland.
US Tax Filing
Because the US taxes are based on citizenship, you may still need to file a US tax return, even if you live and work in Ireland. The US-Ireland DTA agreement is helpful in this instance. It can help you avoid being taxed twice on the same income by claiming credits or exemptions for taxes paid in Ireland.
How to Pay Your Irish Taxes
Once you know what income or gains are taxable in Ireland, here’s what to do next:
- Register with Irish Revenue. If this is your first time paying tax in Ireland, you’ll need to register with Revenue – Ireland’s tax authority – and get a Personal Public Service Number (PPSN). This number is your ID for all Irish taxes and public services, including filing returns and accessing social welfare and healthcare.
- File the relevant tax returns. Depending on your situation, you may need to file:
- Declare foreign income. Include any foreign income you remit to Ireland. Be sure to keep detailed records of all transfers because indirect payments can still count as remittances.
- Pay any tax due. Payments can usually be made online through Revenue’s Online Service (ROS), by bank transfer, or by other approved methods.
- Consider professional help. Cross-border taxation can be complex, and the US-Ireland tax treaty doesn’t cover every scenario. A qualified tax advisor will help you stay compliant and stay clear of double taxation.
Understanding Inheritance Tax in Ireland
If you’re a US expat living in Ireland, it’s important to know how Irish inheritance tax – called Capital Acquisitions Tax (CAT) – might affect you when you receive a gift or inheritance. CAT applies based on:
- Where you live
- Where the assets are located
- Your domicile (permanent home)
You might have to pay CAT when receiving an inheritance or gift if:
- You live in Ireland. If you’re a resident and domiciled, CAT could be due on inheritances you receive from anywhere in the world. Additionally, if you leave assets to an individual they may have a CAT liability – purely because you died as an Irish tax resident/ordinary resident.
- The asset is in Ireland. Property in Ireland is always subject to CAT.
The 5-Year Rule for New Arrivals
If you’ve recently moved to Ireland and aren’t Irish domiciled, you won’t be considered resident for CAT purposes until you’ve lived in Ireland for five consecutive tax years.
This means there’s a five-year window where you can usually receive non-Irish assets (for example, money or property in the US) without paying Irish CAT, as long as the person giving them isn’t an Irish resident either.
After your fifth full year of residence, you become “deemed resident” for CAT, and any worldwide assets you inherit (not just Irish ones) could become taxable in Ireland.
At that point more work is required to determine if the Irish/US Estate Tax Treaty offers any relief.
CAT Thresholds
How much CAT you owe depends on how closely you’re related to the person giving you the money or assets. Ireland divides beneficiaries into three groups, each with its own tax-free threshold.
- Group A (€400,000): Inheriting from a parent (including stepchildren and adopted children).
- Group B (€40,000): Inheriting from a sibling, grandparent, aunt, uncle, or in-law.
- Group C (€20,000): Inheriting from a friend, cousin, or someone not closely related.
If someone inherits more than the tax-free threshold, they’ll pay the CAT rate of 33% on anything over the limit.
Example:
If a father leaves his son €550,000, the first €400,000 is tax-free under Group A (assuming the son had no prior gifts or inheritances in that Group). The remaining €150,000 is taxed at 33%, which comes to €49,500 in tax.
CAT Payments
Capital Acquisitions Tax (CAT) is due based on the Valuation Date – the date your gift or inheritance (cash, property, etc.) is officially valued for tax purposes by Revenue.
| Valuation Date | CAT Pay & File Deadline |
| January 1 to August 31 | October 31 of the same year |
| September 1 to December 31 | October 31 of the following year |
You can pay CAT online using Revenue’s myAccount or ROS portal, or by cheque or electronic funds transfer.
Along with your payment, you must submit an IT38 return form, which reports the details and value of the gift or inheritance for tax purposes.
Estate Planning and Wills
Moving to Ireland means your existing US estate planning documents, including your will, need to be reviewed and updated. This also extends to US trusts – a qualified tax professional in Ireland should review US living trusts or revocable trusts to set out any unforeseen Irish tax outcomes,
Key Steps for Managing Your Wills and Estate
Your US will may not fully align with Irish law, and failure to plan properly can lead to significant complications and delays for your heirs. For this reason, many expats find it simplest to draft a separate, dedicated Irish will specifically for their assets in Ireland. Specialist legal advice should be obtained in Ireland.
Here’s what that looks like in practice:
- Review your US will. Determine if your existing document adequately addresses foreign assets and your change in tax residency. Be on the lookout for potential conflicts with Irish law.
- Draft a separate Irish will. Create an Irish will to govern assets located here.
- Coordinate your wills. Check that your US and Irish wills don’t conflict. Clearly note which will cover which assets and keep copies easy for your heirs to access.
- Think about taxes. A cross-border tax, expatriate or estate planning professional can help you understand how US and Irish taxes apply and how to reduce the chance of double taxation.
- Keep everyone in the loop. Let your executors and beneficiaries know your plans, where your documents are stored, and any important cross-border details.
Who Pays Inheritance Taxes in Ireland?
Unlike in the US, where the estate usually pays federal estate taxes before distribution, in Ireland it’s the heirs who are responsible for paying CAT on any inheritance.
Your heirs could be liable for CAT if any of these conditions are met:
The Asset Is in Ireland (Irish Situs)
Any property physically in Ireland – like land, or a house – is always subject to CAT, no matter where you or your heirs live.
You (the Giver) Are Taxable in Ireland
If the person who passed away (the disponer) was resident or ordinary resident, their worldwide movable assets (like bank accounts, shares, or foreign jewellery) are subject to CAT, under domestic law.
Strategies for Minimising Tax Liabilities
When planning your estate, there are some strategies to help reduce the taxes your beneficiaries may face, like:
Consider Trusts and Life Insurance
- Trusts: In Ireland, trusts can also help delay or reduce CAT for your beneficiaries, (depending on the structure). However review is required to determine if the resulting tax outcome aligns with your plans. Always seek professional advice.Trusts are used less commonly in Ireland to reduce estate taxes than they are in the US so don’t assume it is the right solution without obtaining professional advice.
- Section 72 Policies: These are life assurance policies specifically taken out by a disponer (the person giving the gift or inheritance) to cover the inheritance tax liability arising on their estate. (N.B. Depending on your age they can be expensive!)
Give Gifts While You’re Alive
In Ireland, giving gifts during your lifetime can help reduce the CAT your beneficiaries may owe. A person can receive a gift of up to €3,000 from any one person in a calendar year without having to pay CAT.
As a US citizen, you can also use your US annual gift exclusion (projected at $19,000 per recipient in 2025) to make tax-free gifts without affecting your lifetime US federal estate and gift tax exemption.
Keep in mind that the US-Ireland tax treaty does not cover gift tax, so careful planning and coordination are essential to avoid unexpected taxes in either country.
Coordinate US and Irish Planning
- Review both US and Irish estate and gift tax rules to avoid double taxation.
- Consider which assets should be held in Ireland versus the US to optimise tax outcomes.
- Work with a cross-border tax or estate planning professional to ensure your plans are effective in both jurisdictions.
Expat Taxes Are Always Here with Professional Advice
Understanding the Irish tax system can be tricky, especially as an expat from the US. Without the right planning, your foreign asset, estate, or inheritance could face unexpected costs.
That’s where we come in. Our team specialises in helping US expats like you avoid double taxation and take full advantage of available reliefs and exemptions. We will work with your nominated US Tax Advisor and offer an aligned approach to advising you.
Book a consultation with Expat Taxes today for clear, personalised advice, tailored to your situation and so we can determine next steps. Or drop a note to info@expattaxes.ie to learn more about how we can help.
DISCLAIMER: The material in this article is for general information purposes only and does not constitute legal or taxation advice. Legal, financial, investment and taxation advice should be sought before acting or refraining from acting. All information and taxation rules are subject to change without notice. Expat Taxes Limited (hereafter ‘the parties’) accept no liability for any action taken based on the information in this article or any of the articles on this website.
Written by Mai Clancy, BCL, LL.M, CTA
Mai is a Deloitte-trained Chartered Tax Adviser with over 14 years of experience advising private clients and businesses on Irish tax. She specialises in personal tax, succession planning, and the tax aspects of business disposals, acquisitions, and trusts and estate planning.
