Setting up and running an Irish entity from abroad

Ireland is an English-speaking, common-law EU member with a 12.5% trading rate — which is why companies come. The friction is in the substance requirements, the director rule and the VAT registration, and that is where we work.

In short

A non-resident business establishing in Ireland incorporates a private company limited by shares with the CRO. It must have at least one EEA-resident director or a €25,000 Section 137 bond, a registered office in the State, and — for VAT registration — evidence of genuine economic activity in Ireland, which Revenue now examines closely.

Why Ireland, in practical terms

  • 12.5% corporation tax on trading income, with 25% on rental and investment income.
  • Full EU and single market access, in an English-speaking common-law jurisdiction.
  • An extensive double taxation treaty network.
  • A familiar corporate framework under the Companies Act 2014, with a simple single-document constitution for the standard LTD.

The 15% minimum effective rate under the OECD Pillar Two rules applies only to groups with consolidated revenue above €750 million. Below that, the 12.5% trading rate is unchanged.

The two requirements that delay most setups

Domestic-only or intra-EU VAT registration

The application asks which you want. A domestic-only number lets you trade within Ireland. An intra-EU registration puts you on VIES so you can zero-rate supplies to VAT-registered customers in other member states and account for acquisitions from them.

Intra-EU registration attracts more scrutiny and is harder to obtain. If you genuinely trade cross-border, apply for it at the outset — upgrading later means going through the whole evidence process a second time.

Once registered for intra-EU trade you file VIES statements alongside your VAT3s, and Intrastat once you pass the volume thresholds. Both are easy to acquire and easy to forget.

Substance, and why it is now the whole question

A registered address and a nominee director is no longer a viable Irish structure. Revenue, the banks and increasingly your own counterparties all test whether decisions are actually made in Ireland.

  • Board meetings genuinely held in Ireland, with minutes reflecting real decisions.
  • An Irish bank account, which itself requires substance to open.
  • Employees or contracted people actually doing work here.
  • Premises, even modest, where the activity warrants it.
  • Intercompany arrangements documented at arm's length, with transfer pricing support where the group is in scope.

Opening the bank account

Start this first, because it routinely takes longer than everything else combined. Irish banks want the certificate of incorporation, the constitution, identification and proof of address for every director and beneficial owner, a description of the business and its expected turnover, and evidence of the Irish connection.

Applications with entirely non-resident directorships should expect weeks rather than days, and should expect follow-up questions.

The ongoing cycle

FilingGoes toDue
B1 annual return with financial statementsCROWithin 56 days of the Annual Return Date
CT1 corporation tax returnRevenue9 months after period end, 23rd via ROS
VAT3RevenueEvery two months, 19th or 23rd via ROS
VIES statementRevenueMonthly or quarterly, where intra-EU registered
Beneficial ownershipRBOWithin 5 months of incorporation, then kept current

What it costs

Formation is a fixed fee. The Section 137 bond, registered office and company secretary are annual costs quoted separately. Ongoing compliance is a fixed monthly fee set by activity level, headcount and whether cross-border VAT is in scope. You will have the full picture, including the bond, before you commit to anything.

Sources

Questions we get asked

Do I need an Irish resident director?
You need at least one director resident in the European Economic Area. Without one, the company must hold a Section 137 bond of €25,000 for two years, or obtain a certificate confirming a real and continuous link with an economic activity in Ireland.
How long does it take to set up an Irish company from abroad?
The CRO filing itself is usually a few working days. The realistic timeline is longer, driven by obtaining verified identity numbers for non-resident officers, arranging the Section 137 bond, and opening a bank account — which is normally the longest step.
Why was our Irish VAT registration refused?
Almost always for lack of evidenced economic activity in the State. Revenue examines new applications for genuine substance — contracts, suppliers, premises, an Irish-resident director. Reapplying with a proper evidence pack is usually the route through.
What is the difference between domestic-only and intra-EU VAT registration?
A domestic-only registration allows trade within Ireland. An intra-EU registration puts you on the VIES system so you can zero-rate supplies to VAT-registered businesses in other member states. The intra-EU application attracts more scrutiny, so apply for it at the outset if you need it.
Does the 15% minimum tax rate apply to us?
Only if your group has consolidated revenue above €750 million, under the OECD Pillar Two rules. Below that threshold the 12.5% rate on trading income is unchanged.

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