Ireland

Corporation tax is chargeable as follows on income and capital gains:

Resident companies are taxable in Ireland on their worldwide profits (including gains). 

Profits of a trade carried on in Ireland can generally avail of the 12.5% rate of corporation tax, whereas other categories of income are liable at the higher rate of 25%. Non-trading (passive) income includes dividends from companies tax resident outside Ireland (with some exceptions), interest, rents, and royalties. Legislation provides that certain dividend income (e.g. income from foreign trades) is taxed at 12.5% (see the Income determination section). The higher rate (i.e. 25%) also applies to income from a business carried on wholly outside Ireland and to income from land dealing, mining, and petroleum extraction operations.

An additional ‘profit resource rent’ tax applies to certain petroleum activities. Depending on the profit yield of a site, the tax rate applicable can range from 25% to 40%.

Close companies (see the Income determination section) may be subject to additional corporate taxes on undistributed investment income (including Irish dividends) and on undistributed income from professional services. Examples of professional services include those provided by professionals such as solicitors, accountants, doctors, and engineers.

Non-resident companies are subject to Irish corporation tax only on the trading profits of an Irish branch or agency and rental income from Irish property. Non-resident companies are also subject to Irish income tax (currently at a rate of 20%) on certain Irish-source income, which is generally collected by way of withholding taxes. Capital gains arising to a non-resident company in respect of Irish real estate or Irish mineral or exploration rights, and shares deriving 50%+ of their value from the aforementioned, are subject to Irish capital gains tax (currently at a rate of 33%).  

Pillar Two 

Ireland legislated for the Pillar Two rules with effect from 1 January 2024 for the Income Inclusion Rule (IIR) and Qualified Domestic Top-up Tax (QDTT), and 1 January 2025 for the Undertaxed Profits Rule (UTPR).

Pillar Two aims to ensure that in-scope businesses (those with consolidated group revenues of 750 million euros (EUR) or more in at least two of the four preceding fiscal years) pay at least a 15% effective tax rate on their profits in each jurisdiction in which they operate. The Irish Pillar Two legislation is derived from the Organisation for Economic Co-operation and Development (OECD) model rules and the European Union (EU) Global Minimum Tax Directive. The rules are further supplemented through the OECD guidance. OECD Administrative Guidance issued has been included in legislation with the exception of Administrative Guidance released by the OECD on 5 January 2026.

The rules adopted in Irish Pillar Two legislation, which are derived from OECD Administrative Guidance, include the following provisions (not an exhaustive list):

• Transitional country-by-country (CbC) reporting safe harbour.
• Qualified domestic top-up tax (QDTT) safe harbour.
• UTPR safe harbour.

Ireland has implemented a QDTT via a short legislative provision linked very closely to the IIR and UTPR sections of the legislation. One key aspect of the Irish QDTT is that, where certain conditions are met, the QDTT is calculated using a local financial accounting standard and local financial accounts rather than the ultimate parent entity’s financial accounting standard used in the consolidated financial statements.

As a member of the OECD/G20 Inclusive Framework on BEPS, Ireland has agreed to the Side-by-Side System Package. It is expected that the measures included in that package will be brought in to Irish law by Finance Act 2026, later this year.  

For more detailed information and the most recent updates, please visit PwC’s Pillar Two Country Tracker.

Local income taxes

Ireland does not levy local or regional taxes on income.