Leaving Ireland for Dubai: the three years nobody mentions

Ireland has no exit tax. Revenue does not tax unrealised gains because a person leaves. The official guidance on leaving Ireland covers address changes, ending employment, the PAYE Exclusion Order, split-year treatment and refunds. Nothing about a deemed sale of your portfolio.

That reads like good news, and it is why the actual Irish rule catches so many people. Ireland does not tax you on the way out. It keeps taxing you for three more years after you have gone.

Ordinary residence: three years on your worldwide income

Ireland uses three separate concepts, and you can be one, two or all three: residence, ordinary residence and domicile.

Residence is the day count. You are resident if you spend 183 days or more in a tax year, or 280 days or more across the current and previous tax year combined, with an escape hatch if you spend 30 days or fewer in the current year. The Irish tax year is the calendar year, unlike the UK.

Ordinary residence is the one that follows you. Be resident for three consecutive tax years and you become ordinarily resident from the start of the fourth. Leave after that, and you remain ordinarily resident for three further consecutive tax years, during which Ireland taxes your worldwide income. The exceptions are narrow:

Income type	Treatment in those three years
Trade or profession with no part carried on in Ireland	outside the charge
Employment where all duties are performed outside Ireland	outside the charge
Other foreign income, for example investment income	outside the charge only if it is 3,810 euro or less
Irish source income of any kind	taxable as normal

Read that last-but-one line again. 3,810 euro is a threshold, not an allowance. Below it, nothing is charged. Above it, the full amount is taxable, not the excess. A Dubai brokerage account throwing off 10,000 euro a year means Irish tax on all 10,000 euro, for three years, while you are living in a country that charges nothing on it.

Section 29A: the five year rule for shareholders

The second Irish return rule is narrower and much larger in absolute terms. Section 29A TCA 1997, inserted by Section 69 Finance Act 2003, targets temporary non-residents who hold shares, or rights to acquire them, beneficially held on the last day of the year of departure, where the market value that day was either:

• more than 500,000 euro, or
• 5 percent or more of the company’s issued share capital.

The rule bites when you were Irish domiciled in your last year of residence, you become resident again, and no more than five tax years separate the departure year from the return year. Sell those shares in one of the intervening years and the Capital Gains Tax Acts treat the sale as having happened on the last day of your departure year at that day’s market value. The gain is taxed retrospectively, back in Ireland.

Foreign tax on the same event can be credited, but only where a treaty applies. Ireland has one with the UAE, and the UAE charges nothing on private capital gains, so the credit is worth nothing.

Put the two rules together and the arithmetic is uncomfortable. An Irish founder who wants to sell the company from Dubai has to stay out for more than five tax years under Section 29A, and survive the first three as ordinarily resident. Realistically that is six full calendar years before a return is tax neutral.

The 15 percent that comes off the price, not the gain

If you keep Irish property and sell it later, the headline rate is 33 percent capital gains tax with a personal annual exemption of 1,270 euro. The mechanics are where it hurts.

A CG50A clearance certificate is required for a sale of an asset above 500,000 euro, or a house or apartment above 1,000,000 euro. You only get one if you are resident in Ireland, or if you have already paid the capital gains tax on the disposal.

Without a CG50A the buyer must withhold 15 percent of the purchase price. Not the gain. The price. On a house sold for 1.2 million euro that is 180,000 euro parked with Revenue, recoverable later on a Form CG50B, but gone in the meantime.

The deadlines then run in an order that surprises people:

Step	Deadline
Payment for a disposal between 1 January and 30 November	15 December of the same year
Payment for a disposal in December	31 January of the following year
Return, even where no tax is due	31 October of the following year

You pay on a number you calculate yourself, months before you file it.

Renting it out instead is not passive either. Since 1 July 2023 the non-resident landlord withholding system applies: either you appoint an Irish collection agent, or the tenant must withhold 20 percent of the gross rent and file a Rental Notification within 21 days of each payment. Landlords in that system must file an annual return covering all their income, not just the rent.

Split-year treatment is available if you are resident in your year of departure and not resident in the following year. Claim it, but know how narrow it is: it applies only to employment income. Rent, dividends and capital gains are not covered.

Pensions: the ARF has no exit

Ireland and the UAE signed a double taxation convention in Dubai on 1 July 2010. Article 18 gives the residence state the taxing right over pensions and annuities, so a private Irish occupational pension can be paid gross under a PAYE Exclusion Order. Three things sit outside that:

• An ARF or a vested PRSA is taxed at source on every withdrawal, regardless of where you live. Revenue does not issue PAYE Exclusion Orders for them. In a country where the ARF is the standard retirement vehicle, this is the most expensive assumption people make.
• Public service pensions stay taxable in Ireland under the government service article.
• Voluntary PRSI contributions must be applied for on Form VC1 within 60 months of the end of the last year you paid compulsory contributions, and you need 520 weeks of compulsory PRSI first. Realise in year six that you have gaps and the window has closed, short of ministerial discretion.

The small items that keep running

Child Benefit, 140 euro a month per child, depends on the Habitual Residence Condition. There is no fixed number of weeks, it is a five factor assessment, which means no grace period either. Give up the house and the job and the entitlement stops, and payments that keep arriving are overpayments.

Local Property Tax is tied to 1 November as the liability date, not to your moving date. Hold the property over that date and you owe the following full year, on a valuation fixed from 1 November 2025 through 2030.

Capital Acquisitions Tax on gifts and inheritances is 33 percent above the group threshold, with 400,000 euro for children since 2 October 2024, aggregated across everything received in the same group since 5 December 1991. One caveat we will not paper over: exactly when Ireland charges it where both the giver and the recipient live abroad is not on Revenue’s public pages. Get that answered rather than assumed.

What this means in practice

Ireland is easier to leave than Germany, which taxes unrealised gains on the way out and no longer has a treaty with the UAE. It is harder to leave than it looks, because the whole cost is deferred into the years after the move, when most people have stopped paying attention.

The order that works:

1. Count the tax years. Three consecutive years of residence make you ordinarily resident, and three more after departure is the window in which your Dubai income is Irish income.
2. Decide what your investment income will be during those three years. The 3,810 euro cliff means there is no such thing as a small amount above it.
3. If you hold shares over 500,000 euro or 5 percent of a company, plan for six years out, not five. Section 29A and ordinary residence stack.
4. Sort Irish property before you go. Collection agent or 20 percent withholding for rent, and the CG50A route for any eventual sale, so you never lose 15 percent of a gross price.
5. Check what your pension actually is. An ARF behaves completely differently from an occupational scheme once you are abroad.

The Dubai side is the straightforward half. A company, a residence visa, an Emirates ID and a corporate tax registration all have published fees and fixed deadlines, and you can work the numbers out fee by fee in our company cost calculator. If you are comparing jurisdictions, our notes on leaving the UK cover a system that looks similar from the outside and works very differently.

We handle the UAE half, the accounting, the tax registrations and the deadlines here. The Irish half belongs with an Irish adviser who works with Section 29A and CG50A clearance regularly, and it belongs there before the move rather than after it.

This article is part of a series comparing what leaving costs across fifteen countries. The overview, with a table of every exit charge and how long each tail runs, is in what leaving costs, by country.