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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.
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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.
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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.
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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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