The phrase “exit tax” in Ireland is used to describe at least three genuinely different things. Which one applies to you depends on whether you are a founder moving your company, an investor with Irish-domiciled funds, or an individual leaving the country. Getting the wrong answer is a common and expensive mistake.
This guide covers all three, clearly separated, so you can find the part that applies to your situation. For the full detail on how Ireland’s corporate exit tax works and how to plan around it, see our guide to This article covers the individual-level picture: what happens when a person, not just a company, leaves Ireland. First: what Ireland does NOT have
Before covering what exit tax means in Ireland, it is worth stating clearly what it does not mean, because this is where the most common misunderstanding sits.
Ireland has no general exit tax equivalent to France’s impôt de sortie or Canada’s deemed disposition rules. When you permanently leave Ireland, there is no deemed disposal of your investment portfolio, overseas property, foreign shares, or other assets. No Irish CGT arises simply because you left.
This is a material difference from Germany’s Wegzugsteuer, which treats departure as a deemed sale of all qualifying shareholdings. An Irish tax resident with a substantial share portfolio who moves to Portugal faces no Irish deemed disposal event on those shares simply because they moved.
The important caveats to that general position are what this article covers. Three of them matter most.
For investors: ETF exit tax is triggered when you leave
The term “exit tax” in Ireland is formally used to describe the tax regime that applies to Irish-domiciled ETFs and investment funds. This is the most common meaning for most people searching the phrase.
Under this regime, exit tax at 38% from 1 January 2026 applies to gains on Irish and EU/EEA-domiciled ETFs held under the gross roll-up investment undertaking regime. Exit tax hits Irish-domiciled ETFs and life policies upon departure. The 38% rate applies to gains on these specific assets.
This means that while there is no general deemed disposal of your investment portfolio when you leave Ireland, if you hold Irish-domiciled ETFs, the departure itself is a chargeable event that triggers the exit tax on any gains in those holdings at the date you leave.
The 8-year deemed disposal rule still runs alongside this. ETFs in Ireland sit under a separate regime called exit tax, not the CGT system that applies to ordinary shares. 38% exit tax applies to every gain, with no annual exemption and no loss offset. Every 8 years Revenue makes you pay tax on a profit you have not sold for.
If your departure falls before your 8-year anniversary, the departure triggers a deemed disposal of your ETF holdings at that point rather than waiting for the 8-year date. If you are planning to leave Ireland and hold Irish-domiciled ETFs, this is a planning decision that needs to be made before you move.
For the full worked examples of how the ETF exit tax calculates across different scenarios, see our guide to For regular shares and investment portfolios outside the ETF/fund regime, no deemed disposal occurs on departure. Those assets remain subject to Irish CGT only when you actually sell them, and the rate and whether Ireland can tax the gain depends on your residency and domicile at the point of sale.
For expats: the ordinary residence tail
This is the most common source of surprise for individuals who have left Ireland and assumed their Irish tax exposure ended when they landed abroad.
If you have been tax resident in Ireland for three consecutive years, you remain ordinarily resident for a further three years after you leave. This means you are still liable for Irish tax on worldwide income, excluding employment income from a foreign trade, and worldwide capital gains during this period.
The practical implications are significant. If you leave Ireland in 2026 having lived there for five years, you remain ordinarily resident until the end of 2029. During that period, gains you realise on assets anywhere in the world are potentially within Irish CGT at 33%. The fact that you are living in Germany, the UAE, or the United States does not remove the exposure during the ordinary residence period.
There is one important relief for non-domiciled individuals. A non-domiciled but Irish resident or ordinarily resident individual is liable to Irish CGT on the full amount of gains arising on the disposal of assets situated in Ireland and on the portion of other foreign gains that are remitted to Ireland.
So for expats who are not domiciled in Ireland, the ordinary residence tail creates Irish CGT exposure on foreign gains only to the extent those gains are brought into Ireland. Gains left abroad are not taxable in Ireland for a non-domiciled ordinarily resident individual.
For Irish-domiciled individuals, worldwide gains are taxable in Ireland during the ordinary residence period regardless of remittance.
The ordinary residence tail also applies to Irish property. Selling an Irish holiday home in year one of your departure may still attract Irish CGT, not the CGT of your new country of residence, if you remain ordinarily resident in Ireland.
The 5-year anti-avoidance rule
Ireland also contains a specific anti-avoidance provision under Section 29A TCA 1997 that targets temporary non-residence.
A 5-year anti-avoidance rule means gains on Irish-source assets realised within 5 years of departure can be taxed in Ireland if you were Irish-domiciled.
In practice this means: if you leave Ireland, sell Irish CGT assets while non-resident, and return to Ireland within 5 years, the gains realised during your absence can be brought back into Irish CGT on your return. The provision targets arrangements where someone leaves Ireland specifically to sell an asset in a lower-tax jurisdiction and then returns.
For genuine permanent departures this rule is less likely to create an issue. For individuals who are considering a short-term move to sell a business or significant asset, it is a planning point that needs to be reviewed before the move and before the sale.
For founders: corporate exit tax
If you are a founder or director considering moving your Irish limited company out of Ireland rather than just moving yourself, a different set of rules applies.
The rate of exit tax for companies is 12.5%. An anti-avoidance provision is included to ensure that a rate of 33% rather than 12.5% applies if the exit forms part of a transaction to actually dispose of the asset and the purpose of the exit is to ensure that the gain is taxed at a lower rate. Bundesagentur für Arbeit
The corporate exit tax under Section 627 TCA 1997 applies when an Irish-resident company ceases to be Irish tax resident, typically when management and control moves abroad. The company is treated as having disposed of its chargeable assets at market value at the time it ceases Irish tax residency, with the resulting gain taxed at 12.5%.
For EU/EEA moves, a deferral mechanism is available. For moves to non-EU/EEA countries, the full liability crystallises immediately unless specific relief applies.
Moving yourself out of Ireland does not move your Irish company. If you personally depart Ireland but your Irish limited company remains managed and controlled from Ireland, the company stays Irish tax resident. If you want to move the company as well, that is a separate and more complex question with its own tax analysis.
How Irish tax residency actually ends
Ceasing to be Irish tax resident requires leaving Ireland and meeting the day-count tests. The standard position is that you are Irish tax resident in a tax year if you spend 183 or more days in Ireland in that year, or 280 or more days in total in that year and the previous year combined.
For most individuals, leaving Ireland and spending fewer than 183 days in Ireland in the departure year means non-residency from the following year. The departure year itself is typically a split year between Irish residency and non-residency in practice, though the formal Irish tax year runs from 1 January to 31 December and there is no automatic split-year treatment equivalent to the UK’s rules.
Filing a final Irish tax return for the year of departure is required. Revenue’s Non-Resident Unit handles queries from individuals who have left Ireland. Revenue Online Service is accessible to non-residents with a valid ROS certificate. Download your ROS digital certificate before your myGovID access changes.
The domicile lever: a longer tail than residency
Domicile is a separate concept from residency and operates on a much longer timeframe. For individuals who were Irish-domiciled, the Irish tax net can extend beyond the ordinary residence period in several ways, including inheritance tax exposure on Irish assets and the domicile levy.
The domicile levy of €200,000 per year applies to wealthy Irish-domiciled individuals who spend fewer than 183 days in Ireland but retain significant Irish assets.
Domicile is a complex legal concept and changing it is not straightforward. For high-net-worth individuals leaving Ireland with significant Irish assets, the domicile analysis is as important as the residency analysis and should be reviewed with a qualified Irish tax adviser before departure.
Frequently asked questions
Does leaving Ireland trigger a tax bill on my share portfolio? No. Ireland does not have a German-style deemed disposal of shares or investment portfolios on individual departure. You can leave Ireland holding your shares without a CGT event arising on departure.
Does leaving Ireland trigger exit tax on my ETFs? Yes. For Irish-domiciled ETFs held under the investment undertaking gross roll-up regime, departure from Ireland is a chargeable event that triggers the 38% exit tax on gains, even if the 8-year anniversary has not been reached.
How long does Irish tax exposure last after I leave? If you have been resident in Ireland for 3 consecutive years, you remain ordinarily resident for 3 further years. During this period, worldwide income and capital gains remain potentially within Irish tax. For non-domiciled individuals, the remittance basis applies to foreign gains.
What if I want to move my Irish company abroad? Corporate exit tax under Section 627 TCA 1997 applies at 12.5% on chargeable assets when an Irish-resident company ceases Irish tax residency. This is separate from and more complex than an individual simply changing personal residence.
Does the 5-year anti-avoidance rule affect permanent departures? It primarily targets arrangements where someone leaves temporarily to sell assets in a lower-tax jurisdiction and returns. Genuine permanent departures are less exposed, but the specific facts of any sale during a period of non-residence should be reviewed before the transaction.
The bottom line
Ireland’s exit tax picture for individuals is more favourable than most comparable European countries. There is no general deemed disposal on departure, the ETF exit tax situation is manageable with advance planning, and the ordinary residence tail is finite.
The issues that consistently catch people out are the ETF departure trigger, the ordinary residence tail on worldwide gains, and the distinction between moving yourself and moving your company. All three are planning decisions that need to be made before departure, not resolved afterwards.
Your first consultation with Richmond Blackwood is free. If you are planning to leave Ireland and want to understand your exit tax position across ETFs, corporate structures, and personal residency, get in touch and we will work through the specifics with you.
Disclaimer
This article is for general informational purposes only and does not constitute tax or legal advice. Irish exit tax, CGT, ordinary residence, and domicile rules depend on individual facts and circumstances. Rules described reflect Irish tax law as in force in 2026 and are subject to change. Always take advice from a qualified Irish tax professional before making decisions about your departure from Ireland.
