IRELAND Law and Practice Contributed by: Andrew Quinn, David Burke, William Fogarty and Lynn Cramer, Maples Group
Residential Zoned Land Tax Residential zoned land tax (RZLT) applies to land that is zoned as being residential or for a mix of uses, including residential use that is serviced but has not yet been developed for housing subject to certain exceptions. It is an annual self-assessed tax, calculated at 3% of the market value of land within its scope. The tax applies to land that is included on an annually revised map prepared by a local authority and which is not a residential property – ie, “a relevant site”. RZLT came into effect on 1 February 2025. Landown - ers must register with Revenue for RZLT prior to mak - ing an annual return. The tax falls due for payment on or before 23 May following the liability date to which the payment relates. Subject to meeting certain conditions, landowners may be entitled to an exemption from RZLT for 2026 by submitting a rezoning request to the relevant local authority. To claim this exemption, landowners must have registered for RZLT and filed a 2026 return by 23 May 2026. 2.9 Other Notable Taxes Specific industries may be subject to additional taxes, such as relevant contracts tax (RCT) and professional services withholding tax. Incorporated businesses are also required to withhold income tax on payments to employees and directors of the company (pay-as-you- earn income tax, or PAYE), and to withhold tax at 20% from payments of interest, dividends and certain roy - alties (unless exempted). They must also pay social insurance contributions in respect of employees. 3. Corporations and Non-Corporate Businesses 3.1 Form of Closely Held Local Businesses Most closely held local businesses operate in corpo - rate form. 3.2 Individual and Corporate Rates Further detail on closely held companies is set out in 3.3 Restrictions on Retention of Earnings by Closely
Held Corporations . Closely held companies that are professional services companies are liable to a sur - charge on both undistributed investment and rental income and professional income. This surcharge is 15% of 50% of the annual undistributed professional income, and 20% of all of the company’s undistrib - uted investment and rental income. In addition, Irish Revenue guidelines note that the mandating, allocating or routing through a firm or company of remuneration arising from an individual having or exercising an office or employment does not mean that the remuneration is taken outside of that individual’s income tax rules. 3.3 Restrictions on Retention of Earnings by Closely Held Corporations For Irish tax purposes, a closely held company is a company controlled by five or fewer “participators”, or by any number of participators who are directors. A “participator” is a shareholder or a person having an interest in the company’s capital or interest. Closely held companies are subject to a tax surcharge on investment income (including interest and distribu - tions) or rental income that is not distributed within 18 months of the end of the company’s accounting peri - od. This surcharge is 20% of the undistributed income and is intended to act as a disincentive to individuals using corporates as personal holding companies and availing themselves of corporation tax rates that are lower than the tax rates applicable to individuals. Closely held companies that are professional services companies are liable to a surcharge on both undistrib - uted investment and rental income and professional income, as further described in 3.2 Individual and Corporate Rates . 3.4 Taxation of Individuals on Shares in Closely Held Corporations Irish-resident individuals are liable to CGT at a rate of 33% on the sale of shares in an Irish company (whether that company is a closely held company or otherwise). Non-Irish-resident individuals are generally only liable to Irish CGT on the sale of unquoted shares in an Irish
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