Closing Ltd Company & Moving To Ireland - Tax Question

[Old Greg]

TLDR: if I switch my tax-residency to Ireland in March and subsequently close down my Limited company via MVL, will the money in my company be subject to Irish taxation on top of the tax paid in the UK?

I did this 5 years ago and the advice I got was that the money in my UK ltd.was subject to UK tax (as it was earned in UK), not Irish tax.

[DaaaaaaaaaaN]

I really need to get an Irish accountant. They will go over your figures twice...

To be sure, to be sure....

Tell me about it, I weighed the pros and cons and have decided to remain as a UK tax-resident for the year as it sounds a bit too risky for me given the amount of money potentially at stake.

[northernladuk]

I really need to get an Irish accountant. They will go over your figures twice...

To be sure, to be sure....

[DaaaaaaaaaaN]

I discussed with an Irish accountant who suggested that it would be possible to close down the company via MVL (availing of the 10% Entrepreneur's Relief) in UK and carry over the tax credit to Ireland to offset against a similar Entrepreneur's Relief scheme in Ireland which is also 10%.

[Manic]

CGT in Ireland is pretty horrendous and I imagine the most likely assumption would be CGT at IE rates less credit for the 10% paid in the UK. It all boils down to residency though as you indicate. I would engage an Irish tax expert to help you.

Remember to max your dividends up to the basic rate in the UK this year. If you do move back, and a solution can't be found, it's probably easier just to take the hit at 32.5% and then you can at least get the company struck off cheaply. You can of course pay some into your pension if need be.

[ladymuck]

I think the lack of response is possibly a 'don't know'. Definitely something best to take paid, professional advice on than the free stuff available here.

[DaaaaaaaaaaN]

TLDR: if I switch my tax-residency to Ireland in March and subsequently close down my Limited company via MVL, will the money in my company be subject to Irish taxation on top of the tax paid in the UK?

[DaaaaaaaaaaN]

I have been contracting in the UK for the past two years through my Limited company. My plan after my current contract expires at the end of Feb is to move back home to Ireland as I have landed a nice contract there starting in March.

My problem is that I still have quite a large sum of money sitting in my Limited company that I would like to extract and bring over the Irish sea with me. What I would like to do is close down the company via the usual MVL route and pay the 10% Entrepreneur's Relief tax and be on my merry way. Sadly I have a suspicion that I may not be so fortunate.

Lets say I move to Ireland in March and become an Irish tax resident, then close down my company via MVL in the following months. Would this sum of money then be subject to Irish tax law on top of the 10% already paid in the UK? If that is the case then my plans of moving to Ireland in this financial year are effectively goosed Are there any other alternatives as at the moment the only option I see is sitting out the 183 days in the UK main my UK-resident status.

I appreciate this may be a complicated topic (my accountant is also looking into it), but any advice or discussion would be greatly appreciated!