Non-residents are subject tax on income sourced from Ireland. The following covers various income types and the general source rules for each.
Specific Source Rules for Income Types
Business Profits
The source of business profits is deemed to be Ireland sourced if the underlying operations are carried out in Ireland.
Income from Immovable Property
Income in connection with immovable property or gains from the sale of immovable property is deemed Ireland sourced if the property is situated in Ireland.
Dividend Income
Dividend income is deemed Ireland sourced if the company paying the dividends is resident in Ireland.
Interest Income
Interest Income is deemed Ireland sourced if the payer of the interest is resident in Ireland. In addition, if the payer of the interest is not a resident in Ireland, but has a PE in Ireland which bears the interest, it will be deemed Ireland sourced.
Royalty Income
Royalty income is generally deemed Ireland sourced if the payer is resident in Ireland, or if payment is made in connection with a PE in Ireland.