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Tax residence in Ireland is assumed if an individual has spent more than half a tax year in the country, or more than 280 days over 2 consecutive tax years. If this is the case, they will be taxed on world-wide income. If an individual is resident but not domiciled in Ireland (normally difficult to achieve for an Irish national), they will pay tax on foreign source income only if it is remitted to Ireland. Non-residents pay tax only on income earned in the country.

The International Financial Services Centre created a favourable environment for offshore banking, although there are no specific forms of company or entity designed for ‘offshore’ as such, more a variety of special regimes offering low taxation. However, tax breaks for IFSC companies were abolished by the Irish government after an investigation by the European Union concluded that the scheme constituted state aid, and therefore breached EU competition laws, which attempt to maintain a level playing field across the common market.

By 2003, the IFSC no longer had specific fiscal advantages, but most banks remain there anyway. The centre is host to half of the world's top 50 banks and to half of the top 20 insurance companies. Merrill Lynch, Sumitomo Bank, ABN Amro, Citibank, AIG, JP Morgan (Chase), Commerzbank, BNP and EMRO are just some of the big-name operations that have chosen to locate in the area.

As from July, 2005, Ireland supplies information about the returns on savings paid to citizens of EU Member States, to their home States, under the EU Savings Tax Directive.

 

Isle Of Man

The Isle of Man, with 36 banking operations established, is a prime location for foreign nationals wishing to bank offshore. At the end of June 2010, total deposits stood at a shade under GBP52bn.

The industry on the island is dominated by branches or subsidiaries of the main UK clearing banks, although there are also some foreign banks. Banking services provided range from deposit taking to establishing and administering trusts, managing the underlying companies and assets held by those trusts, and investment management. Banks on the Isle of Man are supervised by the Financial Services Commission.

The Banking Act recognises the contractual duty of a banker to keep the affairs of his customer confidential and the customers' entitlement to confidentiality, other than where disclosure is required to assist criminal proceedings or to enable the FSC to discharge its statutory functions.

All banking licence holders are required to participate in the Depositors Compensation Scheme. The FSC is the Scheme Manager. Initally, deposits were protected up to 75% of the first GBP20,000 per depositor (or foreign currency equivalent). But in 2008, then Treasury Minister Allan Bell announced that the limit of protection for deposits of individuals would be rasied to a maximum of 100% of GBP50,000.

A number of Manx banks offer a range of current and deposit accounts designed especially for non-residents and expatriates. There are no rules to prevent Irish nationals from opening an account in the Isle of Man, whether Irish resident or not. Accounts are available in a number of currencies, and interest rates are comparable with or slightly above those offered onshore. There are also banks offering Internet on-line banking services from the Isle of Man

By concession, deposit interest from Manx banks payable to non-residents (of Man) is exempt from income tax. Isle of Man residents would pay income tax, however.

As from July, 2005, the Isle of Man applies a withholding tax to the returns on savings paid to citizens of EU Member States, under the EU Savings Tax Directive. This is currently 20%, but will rise to 35% on July 1, 2011.



Guernsey

As of September 2010, there were more than 40 licensed banking institutions in Guernsey (all of which are subsidiaries or branches of the top foreign banks), and although the number of institutions has remained approximately the same since the rapid growth period in the 1980's, the deposit base has continued to grow, with only a quarter of the amount held actually in sterling, reflecting the increasing internationalisation of the island's financial sector. Banks are regulated by the Financial Services Commission (as in Jersey), and the capital adequacy rules surpass the Basle requirements. At the end of the first quarter of 2010, the total level of Guernsey bank deposits was GBP118.7bn.

The FSC is extremely careful to exclude doubtful operations, and has capital adequacy rules which are stiffer than the Basle requirements.

A number of Guernsey banks offer a range of current and deposit accounts designed especially for non-residents and expatriates. There are no rules to prevent Irish nationals from opening an account in Guernsey, whether Irish resident or not. Accounts are available in a number of currencies, and interest rates are comparable with or slightly above those offered onshore.

By concession, deposit interest from Guernsey banks payable to non-residents (of Guernsey) is exempt from income tax. Guernsey residents would pay income tax, however.

As from July, 2005, Guernsey applies a withholding tax to the returns on savings paid to citizens of EU Member States, under the EU Savings Tax Directive, initially at a rate of 15%. This increased to 20% on July 1, 2008, but in July 2010, Chief Minister, Lyndon Trott, announced that Guernsey would begin the automatic exchange of information of information relating to interest income earned by EU-resident individuals to their home authorities no later than July 1, 2011.



Jersey

Statistics released by the JFSC in April 2010 showed that over the previous nine years, total bank deposits held in Jersey have increased by more than GBP50bn, achieving a peak in 2007, and declining thereafter. The number of bank licences has declined by 26, mainly due to mergers. At the end of September 2009, there were 47 banks in Jersey, holding deposits of GBP170.6bn. These included subsidiaries or branches of the top banks from the US, the UK, Switzerland, Canada, Germany, Ireland, Israel, the Netherlands and Spain.

Banks are regulated by the Financial Services Commission, and capital adequacy rules are tighter than those under the Basle Convention.

Many Jersey banks offer a range of current and deposit accounts designed especially for non-residents and expatriates. There are no rules to prevent Irish nationals from opening an account in Jersey, whether Irish resident or not. Accounts are available in a number of currencies, and interest rates are comparable with those offered onshore.

By concession, deposit interest from Jersey banks payable to non-residents (of Jersey) is exempt from income tax. Jersey residents would pay income tax, however.

As from July, 2005, Jersey applies a withholding tax to the returns on savings paid to citizens of EU Member States, under the EU Savings Tax Directive. This is currently 20% but will increase to 30% from July 1, 2011.






 

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