Dáil Éireann Debate, Tuesday - 13 January 2026
819. Deputy Pearse Doherty asked the Tánaiste and Minister for Finance if he will provide the total number of non-Irish domiciled companies i.e. incorporated in another jurisdiction but fulfil the tax residency test in Ireland; the number of non-domiciled section 110 companies; and if he will make a statement on the matter. [74051/25]
View answer821. Deputy Pearse Doherty asked the Tánaiste and Minister for Finance the total corporation tax paid by special purpose entities/section 110 companies for the most recent year data is available; and if he will make a statement on the matter. [74053/25]
View answerI propose to take Questions Nos. 819 and 821 together.
Section 110 of the Taxes Consolidation Act (TCA) 1997 sets out the Irish regime for the taxation of qualifying companies set up to securitise assets. Section 110 TCA 1997 sets out a number of conditions which a company must meet in order to be a qualifying company, including the requirement to be tax resident in the State.
Measures were introduced in Finance Act 2014 implementing changes to tax residence rules and these changes are reflected in section 23A TCA 1997. These measures ensure that a company incorporated in the State is regarded as resident for tax purposes in the State, unless it is treated as resident in a treaty partner country by virtue of a double taxation treaty.
Before these rules were introduced a company was regarded as resident in Ireland if its central management and control was performed in Ireland. The changes introduced in Finance Act 2014 do not prevent a foreign incorporated company that is centrally managed and controlled in the State being resident in the State for tax purposes. Therefore, a company which is incorporated in another jurisdiction but managed and controlled in the State is regarded as being tax resident and subject to corporation tax in Ireland on its profits.
I am informed by Revenue that, based on the information contained in corporation tax returns filed, the total number of companies and qualifying companies’ resident in Ireland but incorporated in another jurisdiction is set out in the table below for the years 2020 to 2023 inclusive:
|
Year |
Irish tax resident companies incorporated outside the State |
Irish tax resident qualifying companies incorporated outside the State |
|
2023 |
2,035 |
69 |
|
2022 |
1,969 |
74 |
|
2021 |
1,753 |
72 |
|
2020 |
1,772 |
63 |
I am advised by Revenue that information in respect of 2025 corporation tax payments is not yet available. It will be published in 2026 once the relevant analysis is completed.
In relation to 2024, the most recent year for which data is available, the amount of gross corporation tax receipts paid by qualifying companies amounted to €90 million.
Information in respect of corporation tax paid by qualifying companies is provided in Revenue’s “Corporation Tax 2024 Payments and 2023 Returns” statistical report. This report is published on the Revenue website at: www.revenue.ie/en/corporate/documents/research/ct-analysis-2025.pdf
