J
jambuie
Guest
What determines a "permanent establishment" for a business in Ireland?
I'm a UK IT contractor, with a UK Ltd Company of which I am the sole director. I have the possibility of a contract in Dublin, working 3 days a week there and two days from home in the UK. I would be billing the Irish client company directly from my UK company.
The Double Taxation Treaty between Ireland and the UK would seem to suggest that provided I am not in Ireland for more than 183 days in the Irish tax year, and my company has no permanent establishment in Ireland, both myself as an individual and my company would remain subject solely to taxation in the UK.
My question is, what would constitute a permanent establishment in Ireland? I would be providing my services (IT development) at the client company's office, using their equipment.
I'm a UK IT contractor, with a UK Ltd Company of which I am the sole director. I have the possibility of a contract in Dublin, working 3 days a week there and two days from home in the UK. I would be billing the Irish client company directly from my UK company.
The Double Taxation Treaty between Ireland and the UK would seem to suggest that provided I am not in Ireland for more than 183 days in the Irish tax year, and my company has no permanent establishment in Ireland, both myself as an individual and my company would remain subject solely to taxation in the UK.
My question is, what would constitute a permanent establishment in Ireland? I would be providing my services (IT development) at the client company's office, using their equipment.