27 year old non-resident with €500,000 to invest

Jim2007 said:
By virtue of the various DTAs he has failed to meet the requirements to establish his residence in any other state hence the DTAs nor the convention rules apply. Therefore he remains resident in Ireland.
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Where are you getting this information?

An individual either satisfies the rules of residence of a particular State or does not.

The OP is not the first tax nomad and I daresay will not be the last.
 
Hi Jim

I have looked up the Taxes Consolidation Act 1997.

The definition of residency is prescribed in s. 819

Also, I can not see anywhere in the Act anything that contradicts this.
 
Would a return to revenue not give their take on it. I'd imagine they will at least rule if any monies need to be paid to them, or not. It doesn't have to be taken as gospel, but it would be a start. If it's favourable, accept it, if not, money will have to be spent to get a ruling.
 
noproblem said:
Would a return to revenue not give their take on it. I'd imagine they will at least rule if any monies need to be paid to them, or not. It doesn't have to be taken as gospel, but it would be a start. If it's favourable, accept it, if not, money will have to be spent to get a ruling.
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You mean to fill out an 'Expression of Doubt' ? He will need an advisor for that .... ... (there are rules re EODs)
 
Kildavin said:
You mean to fill out an 'Expression of Doubt' ? He will need an advisor for that .... ... (there are rules re EODs)
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Ok, that's fine, but would it not be the best way to go? After all, he wants finality on this and surely this will give him that. Once he has his Expression of Doubt filed, they will make a ruling and explain (if required) their finding. It would make interesting reading.
 
I think he's paid money for tax-advice from tax-experts and he should adhere to their advice (given individually, and at different stages).

(Unsure if another poster has pointed this out too - but tax treaties are expressly designed to alleviate double-taxation, not non-taxation (although some newer treaties do tackle non-taxation now too)
 
Hi Alwaysonit. I'm in a similar position to you tax wise so I'll let you know how I deal with revenue. I work at sea and spend over eight months a year travelling around the world on a ship registered in the Marshall Islands for a company from Singapore. I file a form 11 every year declaring my foreign income and days out of the country and every year (for a decade) revenue have dedcided I don't owe them a cent. To prove my time abroad I keep my boarding passes, stamps in my passport, sea service records in my seamans book and if necessary a letter from my employer stateing how long I served on their vessels that year. All though I have never been asked for them yet. You will be able to do all these things too apart from the last two obviously. The reason I file a form 11 at all is because I want revenue to be aware of my tax situation and occasionally I do some work in Ireland. Once you have the required days out of the country (and can prove so) revenue seem happy and will leave you be. I claim my DIRT back on Irish deposits too every year.
 
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