New queries, issue 4546

Irish incorporation

The tax implications of converting an Irish branch into a subsidiary company.

We act on behalf of a UK-registered limited company. Business is conducted in the UK as well as in Ireland where the company has been ‘trading as’ an Irish branch since 2007.

The company has three permanent staff in Ireland. They are remunerated through an Irish payroll and the universal social charge (USC) and pay-related social insurance (PRSI) are paid. The company operates in Ireland from permanent rented premises. The branch has modest fixed assets which include two vehicles and one projector.

Between 2007 and 2012 the UK invested £500 000 (about €600 000) into the Irish branch to support its business activities until it became self-sustainable.

The Irish branch made losses until 2014 and these were fully used by the UK company.

Now that it is making a profit we are...