UK → Ireland Tax Guide · 2026
Moving From UK to Ireland 2026: Tax Residence, SARP Relief & Key Differences
Moving from the UK to Ireland is one of the most common cross-border relocations in Europe. But the tax systems differin important ways — from PRSI vs National Insurance and USC (unique to Ireland)to different CGT rates (33% vs 20%) and reliefs like SARP. This guide covers residence rules, split-year treatment, the key tax differences, and what to do with pensions, ISAs, and property. Use our Salary Calculator or SARP Calculator to estimate your take-home pay.
1. Domicile & Residence Rules
Your tax position when moving from the UK to Ireland depends on two concepts: residence (where you live) and domicile (your permanent home). Ireland uses a statutory residence test based on day counts.
📅 Irish Residence Tests (2026)
| Test | Condition | Outcome |
|---|---|---|
| 183-day rule | ≥ 183 days in Ireland in a tax year | Resident for that year |
| 280-day rule | ≥ 280 days across two consecutive years (≥ 30 in each) | Resident in the second year |
| Ordinary residence | Resident for 3 consecutive tax years | Ordinary resident (affects certain reliefs) |
Both arrival and departure days count as days in Ireland.
📌 Split-Year Treatment
If you move mid-year, Ireland's split-year treatment allows the tax year to be divided into a "non-resident" period (before arrival) and a "resident" period (after arrival). This means:
- UK-source income before arrival is taxed only in the UK
- Irish-source income from arrival date is taxed in Ireland
- You avoid paying Irish tax on pre-move UK earnings
- Must make a claim on your Form 11 in your first Irish tax return
2. SARP (Special Assignee Relief Programme)
SARP is one of Ireland's most valuable tax reliefs for incoming employees. It allows 30% of your income above €75,000 to be tax-free for up to 5 years.
📊 Example: SARP on €120,000 Salary
| Annual salary | €120,000 |
| SARP threshold | €75,000 |
| Excess over threshold | €45,000 |
| Tax-free portion (30% of excess) | €13,500 |
| Taxable salary after SARP | €106,500 |
Annual tax saving
€4,050
at marginal rate (40% + USC + PRSI)
Eligibility
Must not have been Irish resident in the 5 years before arrival. Must be coming to work for an Irish employer/related company. Must earn ≥ €75,000 per year (excluding bonuses, shares, and other benefits). Relief available for 5 consecutive tax years.
Claim process
Employer must make a SARP election to Revenue within 30 days of the employee's start date. The employee claims the relief on their Form 12 or Form 11. The relief is applied as a deduction from gross income.
Cap & limits
Maximum salary that can qualify under SARP is €1,000,000. The relief applies to employment income only — not to bonuses, share options, or rental income. If you change employers during the 5-year period, the relief continues if the new employer also signs up.
3. Key Tax Differences: UK vs Ireland
The headline numbers look similar, but the structure is different. Ireland has USC (a third tax layer), higher PRSI for employees, and significantly higher CGT.
| Item | UK | Ireland |
|---|---|---|
| Income tax rates | 20% basic, 40% higher, 45% additional | 20% standard, 40% higher |
| Social insurance | NI: 2%–12% (employee, capped) | PRSI: 4.1% (uncapped above €5k) |
| Extra tax layer | None | USC: 0.5% to 8% (bands) |
| CGT rate | 10%–20% (residential: 18%–24%) | 33% (flat rate) |
| CGT annual exemption | £3,000 (2026/27) | €1,270 per person |
| Dividend tax | 8.75%–39.35% (depends on band) | 25% (flat, plus USC + PRSI) |
| Inheritance tax | 40% (with £325k nil-rate band) | 33% CAT (€400k Group A threshold) |
| Employer social insurance | NI: 13.8% (uncapped from 2025) | PRSI: 11.05% (uncapped) |
4. Salary Comparison: £60k UK vs Ireland
A common question: "What Irish salary gives me the same take-home as £60,000 in the UK?"Here's the comparison.
🇬🇧 UK — £60,000 salary
| Gross salary | £60,000 |
| Income tax (20% + 40%) | -£11,432 |
| National Insurance (12% + 2%) | -£4,646 |
| Take-home pay (annual) | £43,922 |
| Take-home (monthly) | £3,660 |
| Effective tax rate | ~26.8% |
🇮🇪 Ireland — €75,000 salary
| Gross salary | €75,000 |
| Income tax (20% + 40%) | -€16,700 |
| USC (0.5%–8%) | -€3,449 |
| PRSI (4.1%) | -€2,870 |
| Take-home pay (annual) | €51,981 |
| Take-home (monthly) | €4,332 |
| Effective tax rate | ~30.7% |
⚠️ Key Takeaways
- £60k UK (≈ €70k) takes home ~£3,660/month
- €75k Ireland takes home ~€4,332/month
- Ireland's higher effective tax rate (30.7% vs 26.8%) is partly offset by higher gross salaries
- With SARP relief, an €75k earner saves ~€2,025 per year in tax
- Cost of living differences (rent, utilities, groceries) are often more impactful than the tax differential
5. Pensions, ISAs & Property
🏦 UK Pension — Transfer to QROPS or Leave It?
Your UK pension (defined contribution or defined benefit) can be transferred to a QROPS(Qualifying Recognised Overseas Pension Scheme) — typically an Irish PRSA or occupational pension scheme. The transfer is tax-free if done correctly and within HMRC's reporting rules.
✅ Transfer to QROPS (recommended)
- Consolidates pensions in one jurisdiction
- Simplifies Irish tax reporting in retirement
- Avoids FX risk on GBP withdrawals
- No early exit charge (if transferring before 75)
✅ Leave in UK
- Keeps UK tax-advantaged wrapper
- Can take 25% tax-free lump sum (UK rules)
- Withdrawals taxed in Ireland at marginal rate
- Currency risk on GBP/EUR conversions
📈 UK ISA — Leave It Alone
UK ISAs have no protected status under Irish tax law. Once you're Irish resident, interest, dividends, and capital gains within the ISA are subject to Irish tax. You cannot contribute to a UK ISA as a non-UK resident. The simplest approach is to keep the ISA but track its income and gains for your Irish tax return. Consider using your €1,270 annual CGT exemption to crystallise gains tax-free. You may also consider switching to a non-ISA brokerage account for new contributions if you want to simplify reporting.
🏠 UK Property — CGT on Sale
If you own UK property and sell it after moving to Ireland, you pay Irish CGT at 33% on the gain. The UK/Ireland Double Taxation Agreement ensures you get credit for UK CGT paid, but since Irish CGT is higher (33% vs 18%/24% for UK residential), you'll typically have a top-up to pay.
Key points:
- Principal Private Residence relief (UK) may eliminate the gain if it was your main home at the time of sale — even if you've moved to Ireland
- If it was a buy-to-let, the full gain is taxable — no PPR relief
- File a CG1 return in Ireland within 4 months of disposal
- UK CGT return still required within 60 days for UK property sales
- Consider the timing — selling in a year with low other income may reduce your Irish effective rate
6. Moving Checklist
Notify HMRC & Irish Revenue
Tell HMRC you're leaving the UK (form P85). Register with Irish Revenue (myAccount) and get a PPS number. Notify your UK bank and investment platforms of your new address.
Review your employment contract
Confirm your employer supports SARP (if eligible), check share option/RSU treatment across jurisdictions, and understand payroll transition timing.
Plan your pension strategy
Decide whether to transfer to a QROPS or leave your UK pension. Consider an Irish PRSA for future contributions. Check your UK state pension entitlement.
Property & investments
Decide what to do with UK property (sell vs let). Review your ISA and general investment account. Check if you need to file a UK tax return for ongoing UK income.
File your first Irish tax return
Your first Irish Form 11 should claim split-year treatment, SARP relief (if eligible), and double-taxation relief for any UK tax paid. Deadline: 31 October following the tax year.