A directorship is an Irish office holder and is subject to Irish Paye.
To get around this, you will need dual employment contracts with eg €1,000 stated for his directorship duties and the other a salary type amount for the duties performed outside Ireland. You will need to apply to irish Revenue for a PAYE exclusion order on the second employment contract. He can continue to pay PRSI here if he wants.
Yes its a deductible expense for CT, he operates Australian PAYE on his Australian employment contract, Irish PAYE on his directorship contract, PRSI/levies (you decide).
There are serious administration tasks to be performed here by the Irish resident company.
Also watch CGT on companies for non resident shareholders & distributions to non resident shareholders (withholding tax obligations). Are there any Irish resident shareholders in this company - they could be exposed to tax if the non-resident does not pay his taxes.
And no, its not the same invoicing from Australia. Ireland as a company location eg CT rate 12.5%, VAT rules re: EU transactions v imports, etc.
If the directors of the company are non resident in Ireland then the company will no longer be resident in Ireland for corporation tax purpose
If this is correct, Revenue will neither have an interest in the company for corporation tax or PAYE as both of these taxes will be out of scope.
If the directors of the company are non resident in Ireland then the company will no longer be resident in Ireland for corporation tax purpose
If this is correct, Revenue will neither have an interest in the company for corporation tax or PAYE as both of these taxes will be out of scope.
Just because the directors are non resident does not mean the company is non resident.
There are 2 main tests
Incorporation or treaty test
The incorporation test will deem the company resident in Ireland for CT purposes.
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