Direct Taxation
1.23 Remittance Basis for Irish Income
In his 2007 Pre-Budget Report, the Chancellor of the Exchequer announced the removal of the restrictions to the remittance basis in relation to Irish investment and employment income. You will recall that the EU had commenced infringement proceedings in March 2007 against the UK and Ireland in relation to the remittance basis.
The current situation in the UK is that individuals who qualify for the remittance basis of taxation are normally liable to tax on foreign source income only if it is remitted to the UK. But the remittance basis does not apply to investment and employment income arising in Ireland. According to the 2007 Pre-Budget Report Notes, the restrictions will cease to apply from 6 April 2008.
Ireland has yet to amend its rules for the non-application of the remittance basis to UK investment income – Finance Act 2006 had removed the remittance basis for foreign employment income in relation to the duties of that employment exercised in Ireland.
The EU press release on the commencement of infringement proceedings against Ireland and the UK is available at http://europa.eu/rapid/pressReleasesAction.do?reference=IP/07/445&format=HTML&aged=0&language=en&guiLanguage=en.