Ireland is the last major Western European remittance-basis regime standing. For a non-resident with Irish assets, or a family planning a move, the decisive planning happens before residency attaches.
Two kinds of client need to think about Irish tax before they think they do. The first holds assets in Ireland — property, a stake in an Irish company — while living elsewhere. The second is planning to move to Ireland, often from the United Kingdom, where the non-dom regime was abolished in April 2025. For both, the most valuable planning is done before Irish residency and before a succession event, not after.
What Ireland Taxes When You Are Not Resident
A non-resident is exposed to Irish tax on a defined, limited set of things: Irish-source income such as rents and Irish trading profits; Irish dividends, subject to withholding tax and often reduced by treaty; and capital gains on “specified Irish assets” — Irish land and buildings, mineral and exploration rights, and unquoted shares that derive most of their value from Irish land. Your foreign portfolio, held while non-resident, is entirely outside the Irish net.
But there is a tax that does not care where you live: Capital Acquisitions Tax. Ireland charges gifts and inheritances at 33%, and it reaches any Irish-situate asset regardless of where the disponer or the beneficiary is resident — and reaches worldwide assets where either party is Irish-resident. So a non-resident with an Irish house, or with Irish-resident children, has a live Irish inheritance-tax exposure even though income tax barely touches them.
The Clean Division: Irish Assets In, Foreign Assets Out
This produces a simple planning rule. Irish-situate assets — real estate above all — are planned inside the Irish net, for capital gains tax, stamp duty, and inheritance tax. A life policy cannot hold Irish property or shelter Irish-source income, so it plays no part there; the Irish assets are addressed through ownership structuring and, for the inheritance-tax bill, a Section 72 policy. The foreign portfolio is planned separately, outside the Irish net. PPLI, where it is used, is a home for the foreign portfolio only.
The Pre-Arrival Window — the Highest-Value Moment
For a family planning to become Irish resident, the period before residency attaches is the moment of greatest freedom, and two actions matter most.
First, clean capital. A resident non-dom is taxed on foreign income and gains only when they are remitted to Ireland — but once income, gains, and original capital are mixed in one account, Irish ordering rules generally treat any remittance as coming from the most heavily taxed layer first, and the advantage is lost. Establishing and documenting segregated accounts — pre-arrival capital in one, foreign income and gains in others — before the year of arrival is the single highest-value action a mover can take. It cannot be reconstructed retrospectively once the funds are blended.
Second, structure. Where a wrapper is wanted for asset protection or cross-border succession, it is far better arranged before Irish residency and the Irish tax clocks become relevant. For families leaving the UK in particular, this is also the moment to unwind structures built for the old UK regime and realign them with Ireland’s remittance basis. The two systems are not interchangeable, and a structure optimised for one can be inefficient under the other.
Why Ireland, and Why Now
Ireland’s appeal to internationally mobile families has risen sharply for one reason: the UK closed its remittance basis in April 2025, and Ireland’s remains open — indefinitely, with no annual charge, and with no deemed-domicile cut-off. An English-speaking, common-law EU country offering the regime the UK just withdrew is a natural destination, and advisers are seeing exactly that redirection of interest. The remittance basis is the reason to consider Irish residence; it is delivered by holding foreign assets directly and operating clean-capital discipline, with PPLI added only where protection and succession justify it.
The Caveats That Govern the Exit
The move is governed by the law of the country the client is leaving, not the one they are entering, and two points recur. Some origin jurisdictions — France, Germany, and the US expatriation rules among them — levy an exit tax on unrealised gains when a resident departs; Ireland itself has no general individual exit tax, but the origin-country charge has to be modelled before any portfolio is moved or wrapped. And US citizens and green-card holders remain within the US worldwide tax net wherever they live: there is no US deferral because Ireland taxes on remittance, and any policy for a US person must independently satisfy the US tax rules for life insurance, with FATCA reporting on top. In those cases US counsel leads and the Irish plan is built around the US analysis.
The Takeaway for Advisers
For a non-resident with Irish assets, ring-fence the Irish-situate exposure for capital gains and inheritance tax, and plan the foreign portfolio separately. For a prospective mover, do the clean-capital work and any structuring before the year of arrival — the remittance basis rewards preparation and punishes improvisation. And in both cases, treat PPLI as a protection-and-succession tool for the foreign portfolio, structured to stay outside Ireland’s 60% personal portfolio life policy charge, rather than as a way to shelter what the remittance basis already shelters.