Shownotes
Irish residency for expats is only one part of the picture when moving countries. In this episode, Stephanie Wickham speaks with Australian expat Matthew Bliss about the difference between tax residency and immigration residence in Ireland, planning around citizenship and reckonable residence, and the reality of keeping an Australian rental property while living here. They also discuss foreign rental income, cross-border tax returns and the practical workload that comes with managing property from the other side of the world.
Why This Topic Matters
Moving to Ireland can create several different types of “residency”, and they do not necessarily follow the same rules.
This causes confusion surprisingly often. Someone may have permission to live in Ireland for immigration purposes, be building up reckonable residence towards Irish citizenship, and at the same time need to consider a separate test for Irish tax residency.
As Stephanie explains in this episode, the immigration rules and tax rules are not one and the same. The tax legislation contains its own residency tests, so assumptions based on a visa, residence permission or citizenship plan can lead people down the wrong path.
That distinction becomes particularly important when an expat still has property, investments or income in another country.
For Matthew Bliss, an Australian living in Ireland, keeping a rental property in Australia created both tax questions and a much more practical challenge: managing a house, mortgage, tenants, agents and paperwork from thousands of kilometres away.
What Stephanie Covers
Stephanie and Matthew discuss what residence in Ireland has looked like for him personally, including his experience of obtaining residence through his marriage to an Irish citizen and preparing for a future naturalisation application.
They also discuss reckonable residence and why someone planning for citizenship needs to think carefully about time spent outside Ireland. Matthew describes the administrative side of the process and the difficulty of finding a simple answer when immigration information is spread across multiple official resources.
Stephanie brings the tax perspective into that discussion. Tax residency is determined separately, so the number of days that matters for one purpose may not produce the same result for another. For internationally mobile people, this is worth reviewing before making travel plans rather than discovering the distinction afterwards.
The conversation then turns to Matthew’s Australian rental property.
Keeping a property abroad can make sense, particularly where someone is not yet certain that their move is permanent. But there is more involved than collecting the rent each month.
Matthew describes dealing with letting agents, tenant changes, maintenance issues and mortgage administration while working around the substantial time difference between Ireland and Australia. Finding a reliable property manager has been particularly important, although his own experience shows that even this can change when agencies merge or staff move on.
Tax adds another layer.
Matthew discusses completing Australian tax returns, keeping records of property expenses and depreciation, and determining the correct filing position as a resident or non-resident. Stephanie and Matthew also touch on the question of how foreign rental income may need to be considered in Ireland.
For an Irish tax resident with foreign income, the answer can depend on factors including residence, domicile, where the income arises and whether money has been remitted to Ireland. It is exactly the sort of situation where looking at one country’s tax return in isolation can leave part of the picture missing. Matthew himself points out that an Australian self-assessment cannot determine what may need to be declared in Ireland.
What Listeners Will Learn
Listeners will come away with a clearer understanding of why Irish immigration residence and Irish tax residency need to be considered separately.
The episode also highlights why travel can matter when someone is building up reckonable residence for citizenship, and why professional immigration advice may need to sit alongside personalised tax advice where both sets of rules affect the plan.
For anyone moving to Ireland while retaining a rental property abroad, Matthew’s experience is a useful reminder to consider the practical side as well as the numbers. A foreign property may require local agents, reliable record keeping, mortgage administration, tax filings in more than one jurisdiction and calls at some fairly antisocial hours.
Most importantly, cross-border planning works better when both countries are considered together. Tax residency, foreign rental income, domicile, remittances and overseas filing obligations can interact. Sorting out those questions before money is transferred or returns are filed generally gives you considerably more room to plan than trying to reconstruct the position afterwards.
About the Guest
Matthew Bliss is the producer of Taxbytes for Expats and an Australian expat who has been living in Ireland for more than three years.
Working behind the scenes on the podcast has given him an unusual perspective. He has heard plenty of professional advice about relocating internationally, while also dealing with the decidedly less glamorous practicalities himself.
In this episode, he shares what has worked for him, what caught him by surprise and some of the recurring questions he sees from people preparing to make a similar move.
LinkedIn: https://www.linkedin.com/in/matthew-bliss/
Website: https://www.mbpod.com/
Daily Journal: https://journal.matthewbliss.net/
Important Quotes from the Episode
“The rules for immigration, the rules for tax are not one and the same.” — Stephanie Wickham
“As long as you plan ahead, you’re doing the right things.” — Matthew Bliss
“There is still a mental burden to that.” — Matthew Bliss
“If you go into it with your eyes open, you know what you’re getting into.” — Stephanie Wickham
Frequently Asked Questions
Is Irish tax residency the same as immigration residency in Ireland?
No. Irish tax residency and immigration residency are governed by different rules. As Stephanie explains in the episode, tax legislation has its own specific residency tests, which may produce a different outcome from immigration requirements. It’s important to understand how both sets of rules apply to your circumstances, particularly if you’re planning to apply for Irish citizenship.
Can time spent outside Ireland affect my citizenship application and my tax residency?
Yes. Matthew explains that time spent outside Ireland can affect the reckonable residence required for Irish citizenship. Extended periods abroad may create problems when applying for naturalisation. Separately, the number of days you spend in Ireland can affect your Irish tax residency. The two systems have different requirements, so planning your travel carefully is important.
Do I pay Irish tax on Australian rental income after moving to Ireland?
It depends on your personal tax circumstances. The episode highlights that foreign rental income may need to be considered for Irish tax purposes, particularly where you are Irish tax resident. Your domicile and whether rental income has been transferred to Ireland may also be relevant. The episode does not establish that every Australian rental income payment will be taxable in Ireland, so personalised tax advice is recommended.
What happens to my Australian property when I become Irish tax resident?
You can retain and rent out your Australian property while living in Ireland, as Matthew has done. However, you may have tax reporting obligations in Australia and Ireland. Matthew also highlights the practical challenges of managing tenants, property agents, maintenance and mortgage administration from another country, particularly with the significant time difference between Ireland and Australia.
Does domicile affect how foreign rental income is taxed in Ireland?
Domicile can be relevant when determining how foreign income is treated for Irish tax purposes. Stephanie and Matthew discuss how domicile and the remittance of foreign rental income may affect an expat’s tax position. However, the episode does not explain the detailed rules or establish how they apply in every situation. This is worth reviewing with a tax adviser before transferring rental income to Ireland.
Should I file my Australian or Irish tax return first if I have rental income in Australia?
Matthew explains that, in his experience, the Australian tax return generally comes first because the Australian and Irish tax years and filing deadlines differ. However, the correct approach depends on your circumstances and filing obligations in both countries. He recommends working with an accountant who understands the relevant reporting requirements, particularly where foreign rental income and cross-border tax issues are involved.
Related Episodes
Tax issues to be aware of if selling or renting your Australian property
Moving to Ireland from Australia – tax issues to consider
Irish tax residency (know before you go!)
Residency, Relationships & the Realities of Expat Tax with Peter Ferrigno (Part 2)
Voiceover
Welcome to Taxbytes for Expats. The top tax tips you want to know as an expat. The podcast is here to help answer the common queries and concerns expats have when moving to or from Ireland.
Complex taxes explained simply.We’ll focus on the Irish and international tax issues to be aware of to ensure you save time, money, and stress.
Stephanie Wickham
Avoid the hassle of dealing with your bank and transfer online, by app, or over the phone on Currencies Direct today. Keep listening for an exclusive offer for Taxbytes for Expats listeners. But thanks to Currencies Direct for their support of this podcast.
Let’s talk about Residency in Ireland. You know, what that looked like in terms of your situation, preparing for citizenship, you know, very relevant for you, I suppose, because you’ve been in Ireland for a few years now.
Keen to hear your thoughts.
Matthew Bliss
Well, residency is fun, at least for us on the stamp for marriage visa, where the only thing that I had to do was show up to the airport, the customs desk where you give your passport with my wife and say, I intend to stay.
And they give you a special stamp on the passport, and you book an appointment at usually a Garda station. I think there are a few specific spots in Dublin that you can book in as well and set up an appointment to get your residency approved.
The fun bit is the amount of proof that one needs to be able to accomplish this. Because I was married in Ireland, it meant that myOur marriage was on file in this country.
I already had the screws put to me in the test before we were able to get married in Ireland, where they put each of us in separate rooms and asked us the same questions to see if the questions married up.
Yeah, that was a bit of fun. Yeah, that was before we got married. So.I think they front load a lot of the work to reduce the marriages of convenience, I think, to make it a little bit easier from the immigration standpoint.
But I’ve heard that there are some people for their.Various stamp fours requiring proof of income or proof of job, needing a certain amount of money or investment coming to Ireland in order to be able to get whatever residency visa they’re able to get in order to live here.
And there are a ton of circumstances that we always hear about of statuses of refugees and the like that engage in different kinds of visas as well. So I just want to mention that from the very top that I know my experience is going to be a little bit different to some, but at the very least, from my standpoint,The key things for us to get right were going to be the setting up of for naturalization to be able to get the passport.
Which at the time of recording, immediately before the laws change, at least on the stamp four that I’m on, three years of semi regular residence in Ireland.
I think it’s no more than 72 days in any one year or 180 days across three years that you can be absent from the country. Three months of reckonable residence before you apply for naturalization.
And then after three years that you meet that.You’re able to apply for naturalization, which may or may not come within 12 to 18 months of the application.
So.It’s actually very speedy. But do your checks, and you’ll see that there’s a lot of stories at the moment of that being extended from.
Three years with the maximum of five to five years with the maximum of eight.
Stephanie Wickham
Wow.
Matthew Bliss
But there’s also language requirements coming in, which, as far as I know, aren’t part of it at the moment. There’s a bunch of extra rules being layered on top as well.
Like, you can accumulate your years. You only need two, at least two consistently consistent years in the country with reckonable residence if you spent at least six across the last 10 years.
And stuff like that. So the rules are starting to get a little bit more complicated. But if you’re planning for residence, for naturalization and getting a passport in the country, which we want to talk about.
Optimize for as much as we could, then you have to keep that stuff in mind. So, doing a three month summer trip to Spain might not be the best idea, as this audience would be well aware of.
If you’re moving tax residency, then that can cause hassle with your reckonable residence at the same time as your.Domicile impacting where you pay your taxes. And that could also be something that revenue brings up with immigration, or I don’t know what else.
So it sounds like I’m giving you a lot of like question marks regarding the residency. But as long as you plan ahead, you’re doing the right things.
Stephanie Wickham
Yeah.I think as well, clients often say to us, you know, they’ll talk about that reckonable residency piece that you just mentioned. The tax legislation is quite clear. It has a discrete test for residency, which might be impactful.
Because the facts don’t line up then with qualifying or not as the case may be from an immigration perspective. But generally what I say to people is, you know, the rules for immigration, the rules for tax are not one of the same.
And yeah, but I think that’s where it kind of really shows the value of knowing the rules, how they apply to you, how they link in with your plans. And if in doubt, get professional advice from an immigration advisor, perhaps in conjunction with the tax advisor too.
And because obviously we see lots of different types of cases come up.
Matthew Bliss
Yeah. And whatever you do, I mean, we all expect to be able to just Google our way out of these problems, but.Anyone who’s listening to this now will understand this frustration where you Google the issue, you click a page, it takes you to the immigration site.
You click another page, it takes you to another page of the immigration site that also references another aspect of the page you were just on, but it doesn’t tell you exactly where it was.I mean, I don’t want to level something against this country that I love being in, but I think there’s a lot of self referential kind of material that needs a human in the middle to confirm or deny what the actual process is.
Stephanie Wickham
Oh, definitely. Think with something as well, like with residency and your right to live in a country.
Matthew Bliss
You want to get it right.
Stephanie Wickham
You want to get it right, you know?
Matthew Bliss
Um, yeah.
Stephanie Wickham
I, I, I know that from a, from the alternate approach of, I remember I was on a visa in Australia.And arriving on, like, very jet lagged back from Dublin into Perth and being pulled aside by a very frightening immigration officer.
Definitely Australian immigration is way scarier than Irish. I would say that from.Personal experience. If you’ve watched, what’s it called? That program, Border Control? Border Force. Border Force, yeah. It was just something that had been raised on the visa.
But it’s in those moments when you’re jet lagged and then you’re asked a question and you think,Oh, I hope this is fine. That really, you know, having navigated that process with an expert and being confident of where you are, it really kind of brings it home.
Now, thankfully, I think it was just a flag that had been raised on the visa, a question was asked, and it was all fine. But, um,Yeah, it’s, it’s, it’s kind of focusing your mind a little bit when, when you are standing at that desk that you, you need to have this in order because it’s a.
It’s not a right to live in any country if you weren’t born there. So you kind of need to jump the hurdles.
Matthew Bliss
Australia is fun too. Like,They’ll pull you aside at customs where you think that you’ve got a traffickable amount of fentanyl in your bag.And they just want to make sure that your shoes are clean because you might have trod dirt from an Irish field into somewhere in Australia.
Stephanie Wickham
That’s, and I have, I have.Stood behind people who are obviously trying to flout the rules. They’re trying to hide a copious amount of banned.
Fruit and veg in their bag and, and just get through. And then you stand behind them and you think, Oh no, did I, did I visit a farm in the last night?It’s quite frightening when you’re tired and jet packed.
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Check the show notes or head to currenciesdirect.com to register. And thanks to Currencies Direct for the support of this podcast.Tell us about what managing a rental property from Ireland has been like. And I’m really interested to hear the practical side of this because, in consultation with clients, we’ll so often go through the financials what’s it worth?
What’s you going to earn? How’s it going to be taxed?But there’s a real practical piece to trying to manage a rental property from the other side of the world in a different time zone. What’s that been like for you?
Matthew Bliss
It’s not been fun. I’m going to be upfront. I mean, it’s an extremely practical move if.Like us, you didn’t 100% confirm that you’re moving wholesale to the new country.
Like, we didn’t pick up everything, sell it off, and have nothing left in Australia afterwards. Of course, my partner being Irish and me being Australian means that we’ve got a foot in both camps either way.
Managing a rental property, you’d think would be the easiest thing in the world. It turns out there’s far more to it than that.And probably the most primary thing being the first subject in our conversation, having access to an Australian phone number or giving them the international phone number that you’re using.
Is going to be the surest way that you either lose sleep or destroy the rest of your day because the time zones, at least I say this with a lot of hyperbole and exaggeration, doesn’t actually destroy your day.
But there will be mornings that I wake up at 7 30 a.m.I’ll have a brief look at the phone because I don’t like to look at it in the first hour of the day if I can. Have a brief look just in case because you have to.
And there’s an email about something that’s come up with the property.It might be something needs to get approved. It could be something unfortunate has happened between the tenants and.
They’ve had to cancel the lease for whatever reason. And that actually required a phone call, which I had to organize ahead of time. The summer period in Ireland is the best time to talk to Australia because the time difference is only nine hours.
So you’re more likely to catch someone in the middle of their workday.If that ticks over to the other side, it’s 11 hours time difference and it becomes extremely difficult. So, from that perspective, be ready to receive communications at extremelyInappropriate times, if your property requires it in terms of maintenance, getting things approved, cycling rentals, and things like that.
There’s also the economy toThink of it as well. You might have a property that not everyone can afford, or people start buying because the mortgages become more available. And so you start rotating tenants a lot more frequently, which costs you more money, but it also costs you more time and hassle, more things to sign.
You also want to make sure that you have someone decent managing the property. In Australia, a real estate agent is the way to do that. And if you get an agent that you’re happy with, that’s on the level that won’t doThings that you wouldn’t do yourself or will happily communicate with you in the ways that you intend for them to do so, realizing that you’re on the other side of the world.
That’s always the best way to go. Unfortunately, that wasn’t our experience.We signed on to a real estate agent that was absorbed into a bigger real estate company about a month after we left.
So the people that we talked to weren’t even involved.We’ve cycled about three agents managing the property so far, and it hasn’t been great, to be honest.
But, you know, that’s just the way things go. As much as you can prepare, being on the ball is the best way to approach that. So, yeah. And come tax time.
The interesting thing about doing a tax return in Australia is that you have to be on the ball about where and what you need to declare. Obviously, the financial years.
Are staggered a bit to the point where I’ve even asked you a few times, which one do I do first? The Irish one or the Australian one? Generally, the Australian one comes first because of the tax date here in Ireland.
But.Making sure that you’ve got the depreciation schedule if you’re leasing it and it’s the only property you’ve got. Making sure that you declare all of the things that are expenses from the real estate agent in your tax return.
And then, whether you file as a resident or a non resident, I would take advice from the accountant you use. And I would recommend getting an accountant to help you manage that too.
Just like I’m describing here with renting a property from halfway across the world, you can pay as many people as you like to manage as much as you want, but there is still a mental burden to that.
There will also be a mental burden, despite how simple it is for you to go onto the ATO website or whatever the tax website of your country of origin is and do it yourself.
Stephanie Wickham
Yeah.
Matthew Bliss
A self-assessed tax.Won’t be able to tell you from an Australian context whether you’ve remitted any of that rental income to Ireland.
How much you have to declare from here, if any of that income stream is relevant from an Australian context as a non resident, what the state of tax is as a non resident in Australia that you would need to pay, how much you can negative gear against the rest of it.
I don’t even know if that’s relevant anymore because.The Australian CGT rules have changed, and that had an impact on negative gearing for any properties purchased after the 1st of July.
2027, I think.
Stephanie Wickham
Okay.
Matthew Bliss
There’s a lot of complications to it. But anyway, the point is if you are thinking about renting a property, it’s a great move if you want to retain it.But you just need to be aware, like we weren’t, that there is going to be some burden mentally, physically.
You may lose some sleep or wake up with more stress than you imagine trying to get the property managed. And if you have family members and people you know that can help you do that, like my parents have stepped up a lot of times to check out the property.
And do some things there, which has been great. I know not everybody gets to enjoy that kind of luxury.
Stephanie Wickham
So it makes a difference, I think. Yeah, because it’s the time zone is really difficult. You know, you don’t really fully appreciate it.
It just narrows the window during which you can have a conversation where one or other party is not inconvenienced.
Matthew Bliss
That’s it. And our mortgage changed too. Like, we got a great mortgage during the pandemic.And the mortgage provider folded into another bank.
So that was again another phone call where we had to confirm what the new.Details were for that mortgage, blah, blah, blah. There’s more than you can expect, but as long as you’re ready for it.
I guess you’ll be less surprised than we were.
Stephanie Wickham
If you go into it with your eyes open, exactly, if you know what you’re getting into.
Voiceover
Thanks for listening to Taxbytes for Expats. Please do leave a rating or review wherever you listen to your podcast. And as always, remember to take professional tax advice specific to your.
Your personal circumstances before acting or refraining from action in connection with the matters dealt with in this series. The material in this podcast is intended to give general guidance only.
