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HMRC internal manual

Residence, Domicile and Remittance Basis Manual

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HM Revenue & Customs
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Remittance Basis: Introduction to the Remittance Basis: Comparisons with pre-April 2008 regime: Other changes - income arising in the Republic of Ireland

For years before 2008-09 individuals who were resident but not domiciled or not ordinarily resident in the UK were chargeable to tax on the arising basis in respect of any investment income arising in the Republic of Ireland. The same applied to any earnings from employment with an employer resident in the Republic of Ireland.

This meant that the remittance basis was not applied to the individual’s Irish source income even if the individual used the remittance basis for other foreign source income.

Individuals who have previously self-assessed, or been assessed for these earlier years on their RoI income on the Arising Basis will not generally be permitted to alter that assessment unless they are within the usual claim time limits.

For years from 2008-09 the same rules apply to all relevant foreign income and chargeable overseas earnings, regardless of the source of the income or (for Not Ordinarily Resident taxpayers only) the residence of the employer.

Also refer to RDRM31540 Transitional Provisions - Republic of Ireland