Any experience with Ireland LTD setup?

[sky walsh]

Looking for more knowledge on setting up an LTD in Ireland I have interest in moving there more so than Malta.....so this would not be an offshore setup rather I would like to gather the informations about best way to set up for best tax savings while onshore in ireland.I understand CT is 12.5% with a 20% dividend tax. I want to incorporate a stock and Crypto trading business. Does anyone have knowledge about structuring a setup that may do better than the 20% dividend tax? Thank you

 

[Silvio]

The advantage in moving to Ireland is in their non-dom program, similar to Malta. It's not really related to setting up an LTD, more about remitting income or keeping it outside of Ireland\Malta and therefore it remains untaxed in Ireland\Malta.

 

[sky walsh]

The advantage in moving to Ireland is in their non-dom program, similar to Malta. It's not really related to setting up an LTD, more about remitting income or keeping it outside of Ireland\Malta and therefore it remains untaxed in Ireland\Malta.

I will search for this. thank you

 

[sky walsh]

1. Am I correct that a stock and crypto LTD would fall under the 12.5% tax category (active trading) for Corporate Tax?

2. 12.5% tax would be on all the gains that I would have in stock and crypto assets sold during the year?

3. If I were to pay dividends to myself and partner from the years asset gains is the LTD taxed 20% on the distribution? Thought I read somewhere that dividend tax could be 12.5% if the gains were used for the dividend.

4. Also was reading about a holding company being used and having the LTD as subsidiary and a possible dividend withholding tax exception?

5. If I were to keep the gains in the business and than I moved to another EU country would I be liable for a Capitol gains tax or could I sell the assets before moving and pay 12.5% than dispose of the company?

I will see an accountant but would like to be a bit more educated before stepping in the door. Thank you so much for any help and tips

 

[Silvio]

I have no idea about any of these things and you should ask an Irish accountant.

However from what I know if you are a Irish\UK\Malta non-dom you pay 0% tax on whatever you did not remit back to Irish\UK\Malta. So you can just open personal accounts anywhere outside the country you are a non dom in, and use them to trade Stocks\Crypto and pay 0% on whatever profits you generate. No need to complicate it with LTDs.

 

[sky walsh]

The advantage in moving to Ireland is in their non-dom program, similar to Malta. It's not really related to setting up an LTD, more about remitting income or keeping it outside of Ireland\Malta and therefore it remains untaxed in Ireland\Malta.

If I were trading stock and Crypto assets while in ireland

I have no idea about any of these things and you should ask an Irish accountant.

However from what I know if you are a Irish\UK\Malta non-dom you pay 0% tax on whatever you did not remit back to Irish\UK\Malta. So you can just open personal accounts anywhere outside the country you are a non dom in, and use them to trade Stocks\Crypto and pay 0% on whatever profits you generate. No need to complicate it with LTDs.

wow that sounds a lot better. I need to do more research than. I thought CFC rules would apply and that I would need to have substance in the country where the trading company would be setup.

 

[sky walsh]

I have no idea about any of these things and you should ask an Irish accountant.

However from what I know if you are a Irish\UK\Malta non-dom you pay 0% tax on whatever you did not remit back to Irish\UK\Malta. So you can just open personal accounts anywhere outside the country you are a non dom in, and use them to trade Stocks\Crypto and pay 0% on whatever profits you generate. No need to complicate it with LTDs.

when you say personal accounts do you mean an offshore structure or?

 

[Silvio]

when you say personal accounts do you mean an offshore structure or?

I mean you open a personal account in your personal name (NOT a company account), at any bank outside Ireland. Any money\profits that arrive at that bank are tax free. That's the point of being non-dom. If you send this money to your bank account in Ireland, you pay tax. If you keep the money outside Ireland- you pay no tax. Forget about companies and CFC and other headache like this.

 

[sky walsh]

I mean you open a personal account in your personal name (NOT a company account), at any bank outside Ireland. Any money\profits that arrive at that bank are tax free. That's the point of being non-dom. If you send this money to your bank account in Ireland, you pay tax. If you keep the money outside Ireland- you pay no tax. Forget about companies and CFC and other headache like this.

This is very good news for me. So if I understand correctly an EU citizen can move to ireland and take non domicile status....open a personal bank account in Germany or Switzerland and have stock and crypto gains go there. Only money transfered from Personal bank account to ireland is taxable? Would my home country Germany have right to tax though?

 

[hannes]

This is very good news for me. So if I understand correctly an EU citizen can move to ireland and take non domicile status....open a personal bank account in Germany or Switzerland and have stock and crypto gains go there. Only money transfered from Personal bank account to ireland is taxable? Would my home country Germany have right to tax though?

I believe your domicile country would tax your gains. I am somewhat looking for a similar structure for trading in cryptocurrencies.

 

[pippo]

Trying to revive this topic.

hannes, sky walsh, have you progressed in your research for info?

I'm Irish non-dom but never really exploited my status to trade crypto.

Now, the rest of the info I read above do not seem 100% correct to me.

To the best of my knowledge, Capital Gains Tax (CGT) is treated differently from any other Company Tax (CT) or income tax.

Ireland has a punitive CGT for individuals, I can't remember the right figure as my brain felt offended and refused to retain the info, something above 50%. So if you are Irish dom and invest in Crypto, much of it goes to Dublin.

Similar case with an Irish Ltd (CGT rate at 33%), see here: Making money from bitcoin? Revenue has issued rules on paying taxes

What is not clear to me is what happens to Irish non-dom for the non remitted portion. Will that be considered Irish Capital Gain, thus subject to CGT?

From some other articles I read, there's no official position of Revenue on the topic, so it looks like something it may change in the future.

There's like 4.000 non-dom in Ireland. The issue is problably not on the top of politicians' agenda.

I know the UK would consider them as UK based capital gains, nevermind non-dom and non-remittance.

Should anything of the above not be correct, please contradict me: I'd be happy to learn more on the topic.