Remittance to Ireland unusual scenarios for non-dom

This is in relation to non-dom non-PAYE income from bonds and whether its considered remitted to Ireland for income tax purposes

I have encountered 2 scenarios which has left me confused as to whether money was remitted to Ireland - the money in question is income from UK bonds

Scenario 1
A computer monitor was bought with an Amazon.co.uk account and UK bank card with income from bonds and the item shipped to Ireland - is the cost of this item considered remitted to Ireland?

Scenario 2
When you deposit GBP in Trading 212 Markets Ltd it is stored in the following 3 ways

1 in JP Morgan SE (located in Frankfurt),
2 in Barclays Bank Ireland PLC Paris (located in Paris)
3 in Blackrock Sterling liquidity fund which is domiciled in Ireland

Naturally the amount in Blackrock fund is likely remitted to Ireland but the other 2 entities are not based in Ireland - also whats more confusing is Trading 212 is based in Cyprus so technically you are not sending the money to any of these banks you are remitting the money to Trading 212 Markets Ltd Cyprus own account in Frankfurt - what Trading 212 then do with the money is not in your control

For a once off small item, there is no harm in asking this question on askaboutmoney.

But for a material transaction involving cross-border tax issues relating to residence and domicile, you really do need to pay a specialist in the area.

Scenario 1 is 100% a remittance.

Scenario 2 is beyond my expertise to decipher and also depends massively what investments you buy within trading 212. You would also have to keep income separate if you ever wanted to remit capital back to Ireland or else the whole thing ends up as a mixed fund. This really is an area for specialist advice - the right investments, set up in the right way are worth it if you have a reasonable amount of money to invest.

Farma1 said:

Scenario 1 is 100% a remittance.

Scenario 2 is beyond my expertise to decipher and also depends massively what investments you buy within trading 212. You would also have to keep income separate if you ever wanted to remit capital back to Ireland or else the whole thing ends up as a mixed fund. This really is an area for specialist advice - the right investments, set up in the right way are worth it if you have a reasonable amount of money to invest.

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I just deposit the cash income into the uninvested Trading 212 cash account to get the interest on uninvested cash nothing else - they store this money in different ways depending on their own risk profile - of course if I convert to euro and spend it in Ireland it goes into my remittance calculations but the big question is if its just stored in Irish or EU financial institutions or funds by Trading 212 is it remitted ?

Brendan Burgess said:

For a once off small item, there is no harm in asking this question on askaboutmoney.

But for a material transaction involving cross-border tax issues relating to residence and domicile, you really do need to pay a specialist in the area.

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Yes no worries I mean we are talking no more than about 200 quid currently for 2024 but over time this could be a big tax liability if not understood correctly from the outset but I appreciate its complex and probably needs a specialist tax advisor - part of the issue is new challenger banks and fintech companies that store your uninvested cash in various ways unlike a local bank that just stores it in deposit account based in Ireland

BlueHorseShoe said:

I just deposit the cash income into the uninvested Trading 212 cash account to get the interest on uninvested cash nothing else - they store this money in different ways depending on their own risk profile - of course if I convert to euro and spend it in Ireland it goes into my remittance calculations but the big question is if its just stored in Irish or EU financial institutions or funds by Trading 212 is it remitted ?

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I think that classes as deposit income anyway which is reportable for DIRT and wouldn't qualify for remittance basis anyway.

Farma1 said:

I think that classes as deposit income anyway which is reportable for DIRT and wouldn't qualify for remittance basis anyway.

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The interest earned in the uninvested cash account is DIRTable 100% - but the principle sum deposited with Trading 212 in order to earn that interest was interest earned from UK Govt bonds (and that principle sum is actually classed as income as its bond interest and not DIRT deposit interest) this was transferred from a UK account to Trading 212 Markets Ltd (Registered in Cyprus) which in turn stores that money in various banks and funds - the question is whether the income from the bonds transferred to Trading 212 Markets Ltd (Registered in Cyprus) is considered income remitted to Ireland (in the non-dom scenario) - there are 3 entities Trading 212 uses to store uninvested cash - Barclays in Paris, JP Morgan in Frankfurt and Blackrock Sterling liquidity fund (which is based in Ireland)

So far I have calculated that the percentage of the bond interest income that I deposit in Trading 212 which then gets stores in Blackrock Sterling Liquidity fund will likely be considered remitted to Ireland because that fund is Irish domiciled - the other banks used and Trading 212 itself are not based in Ireland so I would imagine that does not count as remittance