When an employee is seconded or assigned to Ireland to work for an overseas employer, there are a variety of issues to be considered including:
- tax residency position of the employee in Ireland;
- how the employee will be taxed in Ireland on employment and non-employment income;
- social security considerations in the home and host (i.e. Ireland) location;
- interaction of Double Tax Agreements in instances where both countries seek to tax income or gains;
- provision of tax efficient relocation allowances or benefits;
- PAYE withholding obligations of the foreign employer in Ireland;
- entitlement to tax relief in Ireland e.g. Special Assignee Relief Programme (SARP);
- potential corporate tax issues; and
- developing policy that incentivises employees to relocate (e.g. offering a guaranteed ‘net’ salary where employer covers some of the Irish tax cost).
We can assist with all of these considerations, as well as offering shadow payroll support and foreign employer payroll registration.