Question UAE Freezone Company - Indian national/ Irish resident.

[cowboy]

Hi All,
I am an Indian citizen, currently living in Ireland for the last 2-3 years. I qualify for the non-dom status in Ireland so my worldwide income is not taxable unless I bring that money into Ireland on a remittance basis as per this source Ireland non-domiciled tax – 10 things you need to know

I am doing some freelancing/technical work and the client is ready to pay my outstanding due (6 figure) to any bank account of my choice. So I am thinking to open a Freezone company + get a residency visa in Dubai and get this payment in a business bank account and visiting Dubai for 2-3 days every 6 months to keep my residency visa valid.

1) Will the UAE bank report/CRS this to Indian/Irish authorities?
2) Will there be a problem while applying for Irish citizenship after 3-4 years considering there will be a UAE residency stamp on my passport at the same time as Irish PR.

Any help would be greatly appreciated.

 

[Fred]

Hi mate,

I can only say again what we had discussed in our personal call:

- The key in this setup is your non-dom status where your worldwide income isn't taxable
- For UAE point of view you are an Indian National becoming Resident in the UAE
- Ireland is out of play because the UAE Banks will onbaord you as a UAE Resident with Residence Visa, Emirates ID and local UAE phone no. - keep in mind there is no Residence Register like we know it from the EU or Western Countries so having Residence Visa, EID and local UAE phone no is within the local UAE framework enough to get onboarded for personal account - you can see this from another perspective as well - for AED only accounts they even don't need your passport - so if you are paranoid - stick to AED accounts only and the bank even doesn't have your Indian Passport on file
- We haven't seen any CRS reporting for UAE Residents (imagine how many people would here complain if it would be otherwise)
- Based on having a Residence Visa for a certain country - there won't be made any decision - never seen or heard that based on your Residence/Long Term Visas a passport won't be granted (US Citizenship excepted) - you can be creative and loose the passport - again if you are paranoid

Cheers

 

[JustAnotherNomad]

I qualify for the non-dom status in Ireland so my worldwide income is not taxable unless I bring that money into Ireland on a remittance basis

I doubt that would make a difference in your case since freelance income likely would count as Irish income, as the UAE company wouldn't have any substance.
But I guess you already knew that since you were asking about CRS.
Also be sure to read this thread: UAE clarification of Freezone Qualifying Income

 

[lifeisfun]

If you have a non dom status in Ireland, it means you are not spending 183 days per year in Ireland. Years in which you did not spend 183 days per year in Ireland will be not counted towards limit set for naturalization. If you spend 183 days per year in Ireland, you do not have a non dom status and you have to pay taxes from your worldwide income.

 

[Cloudbanck]

If you have a non dom status in Ireland, it means you are not spending 183 days per year in Ireland. Years in which you did not spend 183 days per year in Ireland will be not counted towards limit set for naturalization. If you spend 183 days per year in Ireland, you do not have a non dom status and you have to pay taxes from your worldwide income.

No, the 183 days is linked to your status as ordinary resident and tax resident in Ireland.
Domicile status is different, and depends on your roots, citizenship, and intention of staying in Ireland long term. You can live in Ireland several years - possibly indefinitely, and be tax resident in Ireland but not domiciled in Ireland.

See more details here:

Guide to Ireland non-dom

The Irish non-dom status, short for non-domiciled status, is one of the best tax planning opportunities in Europe for location independent entrepreneurs and remote workers. In this post, I explain how it works and detail how to apply. What is non-dom Domicile is not automatic and is not a status...

freedomsurfer.com

What is domicile and the domicile levy?

This page provides an overview of domicile status

www.revenue.ie

https:// nomad capitalist .com /finance/things-you-have-to-know-as-an-irish-non-dom/

 

[lifeisfun]

No, the 183 days is linked to your status as ordinary resident and tax resident in Ireland.
Domicile status is different, and depends on your roots, citizenship, and intention of staying in Ireland long term. You can live in Ireland several years - possibly indefinitely, and be tax resident in Ireland but not domiciled in Ireland.

See more details here:

Guide to Ireland non-dom

The Irish non-dom status, short for non-domiciled status, is one of the best tax planning opportunities in Europe for location independent entrepreneurs and remote workers. In this post, I explain how it works and detail how to apply. What is non-dom Domicile is not automatic and is not a status...

freedomsurfer.com

What is domicile and the domicile levy?

This page provides an overview of domicile status

www.revenue.ie

https:// nomad capitalist .com /finance/things-you-have-to-know-as-an-irish-non-dom/

This is not agains what I wrote.
He want to apply for citizenship in a future.
Only those years are counted towards limit, where he spends ar least 183 days per year.
Person which spends 183 days per year in Ireland is taxed on a worldwide income. If he has no intent to stay in Ireland, he will be not able to apply for citizenship in a future.

 

[JustAnotherNomad]

Person which spends 183 days per year in Ireland is taxed on a worldwide income.

Only if they are domiciled in Ireland. If they are not domiciled in Ireland, then they can spend 183+ days in Ireland, but would not be taxed on their worldwide income.

 

[Cloudbanck]

Only if they are domiciled in Ireland. If they are not domiciled in Ireland, then they can spend 183+ days in Ireland, but would not be taxed on their worldwide income.

Exactly, when you apply for citizenship though, you may be deemed to have domicile in Ireland, as that is a clear intention to stay in Ireland long term. And keep in mind that it can take a year and a half from citizenship application to when you actually receive the passport.

 

[JustAnotherNomad]

Once you apply for citizenship, could they retrospectively claim you had an intent to stay in Ireland?

 

[Cloudbanck]

Once you apply for citizenship, could they retrospectively claim you had an intent to stay in Ireland?

I can't find a clear answer to this, but I really don't think so. Changing things retroactively goes against Irish and Western legal tradition and principles.

This text was quite detailed and interesting about non-dom status. Says you can't have domicile in two countries at the same time, which would point against retrospective change of status.

http://publications.ruchelaw.com/news/2015-12/Vol2no10_04_Ireland_Non-Dom.pdf

Apparently if you have been a non-dom in Ireland for like 20-30 years, maintaining a burial plot in the country of foreign domicile is a good idea, to keep the non dom status.

 

[bonox]

This is not agains what I wrote.
He want to apply for citizenship in a future.
Only those years are counted towards limit, where he spends ar least 183 days per year.
Person which spends 183 days per year in Ireland is taxed on a worldwide income. If he has no intent to stay in Ireland, he will be not able to apply for citizenship in a future.

you get that information from where ?