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Sub Contractor starting work in ROI

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Have a quick query if anyone could help it would be greatly appreciated.

I have a client who is setting up as a sub contractor in Dublin (Republic of Ireland), doesn't currently have a UK company, works for his father who is a sub contractor. ( All based in Northern Ireland)

He doesn't have a Irish address, advised he will need to get this as he will have to set up Irish company for RCT payments, according to the irish revenue he can reclaim all the RCT which is then declared through the UK (presumably will go through a UK company which he will need set up) if he doesn't have to register for CT in the ROI. This only will happen if the job he is working on lasts less than 6 months? So he can put everything through a UK company.

On the other hand if he is to register for CT if the job lasts longer than 6 months in the south then he will pay CT on his trading income in ireland. If this is the case he can benefit from the 12.5% Corporation Tax in Ireland.

I was wondering after that does he just pay himself a dividend in the South and then file a Irish tax return and UK tax return benefitting from the double taxation agreement or does he transfer the Irish profits to the UK company and pay himself a dividend? 

Would the UK company be subject to the extra % of CT owed on profits as their is only 12.5% paid in Ireland


Please correct be if I am wrong and advise any better way of doing this

Replies (3)

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11th Nov 2019 13:18

I can't make head or tail of your question. You need to start again, in grammatical english.

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Replying to JDBENJAMIN:
By Accountant A
11th Nov 2019 14:19


I can't make head or tail of your question. You need to start again, in grammatical english.

I think it lost credibility when he said "I have a client ...".

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By unearned luck
11th Nov 2019 23:47

What's amusing about this is that the OP is asking members for the answer to a complex international tax issue but assumes that members don't know that Dublin is in the Irish Republic.

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