Indian-Irish remittance basis: Indian income stays tax-free if you don't bring it in.
TL;DR
Unlike the UK (which abolished its non-dom regime in April 2025), Ireland still has a remittance basis for non-domiciled residents. They pay Irish tax only on Irish-source income and on foreign income they remit to Ireland. For Indian-Irish, this is one of the most NRI-friendly setups in Europe.
By Vipul Sharma, Founder
Reviewed by Preetesh Maloo, Chartered Accountant, NRI Tax Partner
What 'remittance basis' means in Ireland
Ireland's tax law allows a tax-resident-but-non-domiciled individual to be liable to Irish tax on Irish-source income (full amount) and foreign-source income only if remitted to Ireland. The Indian-side counterpart is Section 6 of the Income-tax Act on residency.
Domicile is a common-law concept. For most Indian-Irish, your domicile of origin is India (you were born there, your father was Indian-domiciled). Acquiring Irish domicile-of-choice requires both physical residence in Ireland and an unequivocal intention to settle there permanently. Most Indian professionals on work visas don't meet the second test.
So in practice, Indian-Irish on work visas are tax-resident in Ireland (over 183 days) but non-domiciled. They qualify for the remittance basis automatically.
The Irish government hasn't followed the UK's April 2025 FIG abolition. As of 2026, the Irish remittance basis remains intact.
What remittance basis exempts and what it doesn't
Tax-free in Ireland (if not remitted):
Indian salary credited to an Indian bank account.
Indian rental income kept in India.
Indian dividends received in India.
Indian capital gains realised and held in India.
Fully Irish-taxable (no remittance test):
Irish-source employment salary.
Irish-located property rental.
Irish bank interest.
Irish capital gains on Irish assets.
Foreign income that IS remitted (transferred to Ireland):
Direct transfer from Indian bank to Irish bank: taxed at full Irish rates.
Using an Irish credit card to spend in Ireland against an Indian-funded credit balance: counts as remittance.
Reimbursing yourself in Ireland for India-paid expenses: remittance.
The planning lever: keep foreign income in foreign accounts. Bring in only the salary you actually need to live in Ireland.
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India-side: Article 11 still applies
The Irish remittance basis is Irish-side only. India's source-based taxation under Section 9 still applies to Indian-source income.
For an Indian-Irish with a ₹40 lakh NRO FD at 7% earning ₹2.8 lakh annually: Indian default TDS is 30% under Section 195. With Form 10F + Irish Revenue TRC, the rate drops to 10% under Article 11 of the India-Ireland DTAA. Annual saving: ₹56,000.
If the NRO interest stays in India (not remitted to Ireland), the Irish side claims nothing on it. So the structure becomes: Irish DTAA brings Indian TDS down to 10%; remittance basis keeps Irish tax at 0% on the Indian-side income; net effective rate on the same income is 10%.
Compare to a domiciled Irish resident: Indian 10% + Irish marginal slab rate (up to 52% with USC and PRSI) on the worldwide income, less FTC. Net effective could be 40 to 50%.
The Irish non-dom advantage on Indian-source income is real and substantial.
The math on a typical Indian-Irish position
A Dublin-based Indian software engineer:
Irish salary: €120,000 (Irish-taxed normally at marginal rates).
Indian NRO interest: ₹3.5 lakh annually.
Indian rental: ₹6 lakh annually.
Indian dividends: ₹1 lakh annually.
Indian-side filing: Form 10F + Article 11 + Section 9. NRO interest at 10%: ₹35,000 TDS. Rental at 30% slab (after standard deductions): ~₹1.5 lakh. Dividends at 10%: ₹10,000. Total Indian tax: ~₹1.95 lakh on ₹10.5 lakh of Indian income.
Irish-side filing under remittance basis: Indian income is NOT remitted, NOT taxed in Ireland. Irish tax = on €120,000 Irish salary only.
If the engineer remits ₹2 lakh to Ireland for a holiday: that ₹2 lakh becomes Irish-taxable at the marginal slab. ~50% Irish tax = ~₹1 lakh additional.
Keep the Indian funds in India. Plan remittances carefully. The structural saving is ₹4 to 5 lakh per year on a typical professional's portfolio.
What we actually do for Indian-Irish residents
We handle the Indian side. The Irish remittance-basis filings need an Irish accountant. We coordinate with theirs.
Indian-side scope: Form 10F / Form 41 refile, Irish Revenue TRC liaison, NRO interest recovery via the 10% Article 11 rate, Schedule FA filings (above ₹20 lakh safe harbour), ITR-2 with foreign-asset disclosure, Section 119(2)(b) condonation for past years.
Pricing is success-fee based on recovered Indian TDS (no recovery, no fee). Annual filing and Form 10F / Form 41 renewal are both small flat fees, quoted on the call.
If you've been in Ireland 1 to 5 years and you haven't formalised the remittance-basis position with your Irish accountant, book free CA appointment. The remittance-basis claim is annual; missing the election once costs the year's exemption.
Frequently asked questions
Q: I've been in Dublin for 8 years. Am I still non-domiciled?
A: Domicile is a question of intent, beyond mere years of residence. If you haven't bought a permanent home in Ireland, kept Indian family ties, and consistently planned to return, you can argue non-dom status indefinitely. Get a written domicile memo from your Irish accountant after year 5 to defend it during scrutiny.
Q: I bought a Dublin apartment to live in. Does that change my domicile?
A: Buying a home is one factor, not the only factor. Irish Revenue looks at intent: where do you plan to be when you retire? Where's your spouse's family? Where do you maintain bank accounts? A property purchase doesn't auto-flip your domicile, but it shifts the burden of proof.
Q: My India dividend was credited in 2025 but I haven't remitted it. Irish-tax-free?
A: Yes if you've claimed remittance basis on your Irish tax return for 2025. Keep the dividend in your NRO account. The Irish side claims nothing.
Q: I used my Irish-issued credit card to buy a flight to Mumbai. Remittance?
A: It depends on how the card is funded. If the card balance is paid from an Irish bank account, no remittance. If it's paid from an Indian-source-income account directly, remittance. Set up a clean Irish-funding loop.
Q: Can I lose remittance basis by becoming Irish-domiciled?
A: Yes. If you formally acquire Irish citizenship, sell Indian property, marry an Irish national, and signal permanent settlement, your domicile can shift. This is a 5 to 15 year process. Plan transitions carefully. Book free CA appointment if you're considering Irish citizenship and you have substantial Indian-source income.
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NRO account: what it costs and what it caps
Right now: Interest taxed at 30% plus surcharge and cess; repatriation capped at USD 1 million a financial year
Where it works differently
- A TRC and Form 10F (Form 41 from 1 Apr 2026) are furnished
- The treaty rate applies to the interest, commonly 10-15% under Article 11 instead of 30% plus surcharge.
- s.90(2). This is the single largest recurring recovery item for most NRIs.
- Remitting out
- Form 15CA is needed, plus Form 15CB from a CA where the remittance is chargeable and above Rs 5 lakh in the year.
- Rule 37BB.
- Joint holders
- The USD 1 million ceiling is per person per financial year, so joint holders each have their own.
- FEMA 13(R).
Commonly got wrong
- NRO interest is taxed at 30%. Incomplete. Surcharge and 4% cess sit on top, and a treaty can cut it to 10-15%.30% plus surcharge and cess by default, but 10-15% under most treaties if you hold a TRC and file Form 10F.
TDS on NRO account interest
Right now: 30% plus surcharge and cess
Where it works differently
- A valid TRC and Form 10F (Form 41 from 1 Apr 2026) are furnished
- The treaty rate applies, commonly 10-15% under Article 11.
- s.90(2) gives the more beneficial of treaty or Act.
- No PAN is furnished
- s.206AA imposes at least 20%, but Rule 37BC allows escape by furnishing name, address, TIN and TRC. Courts have also held s.206AA cannot override a treaty rate.
- Rule 37BC + settled case law.
- Claiming the treaty rate at source
- The s.115A(5) filing exemption is lost, so an Indian return becomes necessary.
- That exemption requires TDS at not less than the s.115A rate.
- The account is NRE or FCNR instead
- Interest is exempt and no TDS applies, while the holder is a FEMA non-resident.
- s.10(4)(ii) and s.10(15)(iv)(fa).
Commonly got wrong
- NRO interest TDS is 30%. Incomplete. Surcharge and 4% cess sit on top, so the effective rate is higher.30% plus surcharge and cess, around 31.2% at the base level.
- You can file Form 15G/15H to stop NRO TDS. Those are resident-only declarations. An NRI filing one makes a false declaration.Use Form 13 (Form 128 from 1 April 2026), or claim the treaty rate with a TRC.