International Tax Planning
Irish corporation tax, R&D credits, and cross-border structuring — advised by K&L Global
K&L Global does not provide formal tax advice and is not a registered Irish tax adviser. All formal tax advice and all Revenue filings are prepared or supervised by licensed Irish-qualified tax professionals working with us. |
International Tax Planning — Ireland — K&L Global Ireland Desk
K&L Global advises on Irish corporation tax, double taxation treaties, the Knowledge Development Box, R&D Tax Credit, and cross-border structuring for Irish entities.
What K&L Global does — International Tax Planning
Assess the optimal ownership structure for an Irish company (direct shareholding vs. holding company)
Identify the applicable double taxation treaty and the withholding rates available for cross-border payments
Advise on R&D Tax Credit eligibility and the documentation required to support a claim
Advise on KDB eligibility for companies whose trade involves IP
Co-ordinate with Revenue-registered Irish tax advisers for formal tax advice and CT return preparation
Provide English-language explanations of Irish tax positions for non-Irish group tax functions
The Irish corporation tax landscape in 2026
Trading income: 12.5%. Applies to profits of a trade carried on in Ireland. Source: https://www.revenue.ie/en/companies-and-charities/corporation-tax-for-companies/corporation-tax/basis-of-charge.aspx
Passive / non-trading income: 25%. Applies to rental income, investment returns, interest, and dividends from non-qualifying sources. Same source.
Capital Gains Tax (CGT): 33%. The Substantial Shareholding Exemption (SSE) may apply to disposals of qualifying trading subsidiaries resident in EU member states or treaty countries — the gain is CGT-exempt where the parent holds at least 5% for a minimum of 12 months and the subsidiary is a trading company. Source: https://taxsummaries.pwc.com/ireland/corporate/income-determination
Pillar Two — 15% global minimum tax: Applies to MNE groups with consolidated revenues of €750 million or more. First Irish top-up tax return due 30 June 2026 for December year-end groups. Does not apply to the vast majority of K&L Global's clients. *Source: https://www.revenue.ie/en/companies-and-charities/international-tax/pillar-two/index.aspx
Tax Type | Rate |
Trading income | 12.5%. |
Passive / non-trading income | 25% |
Capital Gains Tax (CGT) | 33%. |
KDB | 6.25% |
R&D Credit | 30% |
Pillar Two | 15% |
R&D Tax Credit (2026)30%R&D Tax Credit Credit on qualifying R&D expenditure carried out in Ireland • Offset against corporation tax liability • Excess credit can be: – Carried back one year – Paid as cash refund (in instalments) – Offset against payroll taxes • Valuable for loss-making start-ups (cash refund mechanism) (* Source https://www.revenue.ie/en/companies-and-charities/reliefs-and-exemptions/r-and-d-tax-credit/index.aspx ) |
Knowledge Development Box (KDB)6.25%Effective Tax Rate (KDB) Reduced corporation tax rate on income from qualifying IP developed in Ireland • Applies to patents and software • Based on OECD “modified nexus” approach • Linked to R&D performed in Ireland • Limited benefit if R&D is outsourced to related parties |
Double taxation treaties
Ireland has concluded double taxation agreements with 75 countries as of 2026. These treaties typically reduce or eliminate withholding taxes on dividends, interest, and royalties paid between treaty partners. Source: https://www.revenue.ie/en/companies-and-charities/international-tax/double-taxation-agreements/index.aspx
Holding company considerations
Ireland is a common location for European holding companies because of:
12.5% rate on dividends from trading subsidiaries resident in the EU or in DTT countries
Substantial Shareholding Exemption for CGT-free disposal of qualifying trading subsidiaries
No withholding tax on dividends paid by Irish companies to EU or treaty country shareholders in most cases
Participation exemption for dividends from certain foreign subsidiaries
K&L Global advises on whether an Irish holding company structure is appropriate for your group, and co-ordinates the formation and ongoing compliance with specialist Irish tax advisers.