From big infrastructure projects to city trading floors, NHS hospitals and school staff rooms, you’ll hear Irish accents everywhere in the UK. A stint working “across the pond” is still common for Irish people.
Higher earnings, international experience and proximity to home make the UK the most popular destination for Irish emigrants. It’s no surprise that London-Heathrow is Dublin, Cork and Shannon airports’ most popular route, according to CSO figures. From Knock, it is London Luton.
Every year, many Irish return to Ireland, too – to settle down, buy a home or get their kids into school. If you’re coming back with a few bob, here’s how to mind it.
“We talk to an awful lot of Irish returning from the UK,” Stephanie Wickham of Expattaxes.co.uk says. “They have a successful career there, they are in management or c-suite roles, maybe they have married there. They have accumulated wealth and savings and are looking to come back.”
Her company has recently expanded its tax consultancy services in response to the volume of Irish people returning home and a high number of British-born people relocating here too.
Some returning Irish are business owners, attracted back by what they see as a friendlier tax environment, she says. Others are UK-born, have the right to an Irish passport and see the attraction of Ireland post-Brexit.
And it is not just retirees coming back. There is a younger cohort who have worked a number of years in London, made some money and now want to settle down in Ireland, says Frank Mulcahy, of Trinity Financial Management.
From bank accounts to investments and pensions, returners should seek advice on how to preserve their wealth before the move, he says.
Individual savings accounts (ISAs)
Many Irish living and working in the UK have availed of the popular Individual Savings Account, known as an ISA. This is a tax-efficient savings and investment product available to UK residents and allows a person to save up to £20,000 every tax year.
A cash ISA is a savings account; a stocks and shares ISA is an investment account where your money is invested in stocks, shares, bonds, funds and other investments. ISAs allow tax-free growth in the UK.
“If you have the capacity to contribute, ISAs can be a smart thing to do,” Wickham says.
But what happens when you return to Ireland?
“There can be this assumption that Ireland is going to give you the same tax exemptions and the reality is it does not,” she says.
The interest on cash, dividends from investments and capital gains from the disposal of assets in an ISA are generally taxable under Irish law if you are tax resident here.
Ireland’s offshore fund regime taxes foreign investments in a fairly punitive manner, Wickham says. Returning Irish people who hold ISAs can get hit with a punitive flat rate 41 per cent tax on gains in an ISA account, she says.
“What we commonly see with those coming back is they are caught by some of these offshore rules.”
Your specific type of ISA will determine how it will be taxed in Ireland.
“If a client comes to us with an ISA, really the message to them is to have it looked at with a tax adviser before you become tax resident in Ireland because it may not have the same tax advantages attached to it as you expect or were familiar with in the UK,” she says.
If you have returned to Ireland permanently, but kept a UK stocks and shares ISA that is up 20 or 30 per cent then you will have to pay full Irish capital gains tax on it if you sell it, Frank Mulcahy says.
Sell a stocks and shares ISA before returning to Ireland and it would be tax-free to take the money out, he says.
And if the ISA is a fund investment, you will pay 41 per cent exit tax, which is higher than any UK tax, Mulcahy says.
“If you don’t act before you leave the UK, you could find yourself paying more tax than you need to pay,” he says.
Those planning to go back to the UK at some point in the future should leave the ISA there, Mulcahy says.
Cash
If you’ve accumulated savings in a UK bank account, should you just transfer them to a bank account here?
People are often concerned that the transfer of a lump sum is going to cause problems, Wickham says.
“The income that gave rise to the savings happened before you became an [Irish] resident, so, broad stroke, that is generally not a problem for Revenue,” she says.
“Our [capital] tax system here is self-assessment, taxpayers are required to assess their own tax liability. It’s not that Revenue would actively police every bank transfer, but more that you must understand what your tax obligation is with respect to certain types of income gain.”
In addition, currency fluctuations can have a big impact on your pot. Using a currency broker, instead of transferring the money through a high street or online bank, can pay off – particularly for large sums. Getting a positive rate on your foreign exchange can save you thousands.
Making a gain like this could, however, also leave you open to tax, Mulcahy says.
Property – stick or twist?
Some people who have lived and worked in the UK may own a flat or house there. Returning immigrants can misunderstand their tax obligations regarding rental income, however, Wickham says.
“There can be a misconception that, ‘Well I’ve paid my tax in the UK on the rental income and I don’t need to say anything to Revenue in Ireland because of double taxation agreements’,” she says.
That’s not the case.
“With rent, you would declare it to HMRC [HM Revenue & Customs], where you have an obligation to file a return and pay the tax, and you also need to include that in your Irish tax return,” she says.
“Both jurisdictions have the right to tax the rental income, though the mechanism by which the tax is applied [under the double taxation agreement] will give credit in Ireland for taxes already paid in the UK.
“Sometimes people boil that down to ‘I just pay tax in one country’, but you’ll be taxed in both countries though a credit is provided so you are not doubly taxed on the same income.“
If the UK property is held jointly by a married couple, for example, they could consider reviewing matters before they return.
If one of you remained tax-domiciled in the UK, their portion [of the rental income] would not be taxed in Ireland if they did not bring that income over to Ireland or to an Irish bank account, Wickham says.
So before returning, consider the implications of tax domicile. Domicile can be a complex and legal concept. Get tax advice to work out if there is potential for you to save on the Irish tax liability, she says.
“Some who are DIY-ing their tax return may be overpaying Irish tax or just not considering the opportunities for a potential saving. It is misunderstood by clients frequently,” Wickham says.
Capital gains tax
The UK budget will be unveiled towards the end of November and changes to capital gains tax are mooted.
“People are worried about general increases to the tax base in the UK because it appears there are changes coming,” Wickham says. Some Irish people are looking to take their businesses out of the UK tax net and they see Ireland as a more favourable jurisdiction.
While Irish tax rates for individuals are quite high, these can be favourable for ex-pats who do some tax planning in advance of their relocation back, she says.
You pay more tax when you sell an investment in Ireland than you do in the UK, Mulcahy says. That includes capital gains tax in Ireland, which he describes as a “kind of draconian exit tax”.
“You are far better off restructuring your affairs and selling out of your investments in the UK before you return to Ireland,” he says, if you do intend to sell up at all. Some people will send the proceeds to Ireland before they become tax resident here, he says.
“That sounds very tax-strategised, but it’s a very practical thing because if you sell them after you come over to Ireland and you are resident here then you have a whole new Irish system to deal with.”
If you do intend to sell your property in the UK then you would be better off doing so before returning as tax on gains is lower there.
Pension
If you have a pension or pensions in the UK, generally you would leave them there, Mulcahy says. Speak to a UK pension adviser before leaving. They may recommend you consolidate pensions from different jobs, he says.
It’s not necessary to bring your UK pensions to Ireland, Mulcahy says.
“We have a very similar system here to the UK system. Ireland recognises UK pensions and there are the same tax/lump sum withdrawal rules,” he says. “You could easily leave them in the UK and then access them at retirement here.”
Post-Brexit, there is an agreement that provides for a cross-border social insurance coverage, Wickham says. Irish citizens living in Ireland maintain the right to benefit from social insurance contributions made when working in the UK.
“That can mean if you’ve worked in the UK for a period, you may have an entitlement to a UK social insurance pension,” she says.
To qualify for the minimum UK state pension, an Irish national must have 10 “qualifying years” on their UK National Insurance record.
If you spent less than 10 years working in the UK before returning to Ireland, you can still claim the UK state pension from Ireland if you fill in the “gaps” in your National Insurance record. You can do this by making voluntary National Insurance contributions to purchase “qualifying years”.
You can make voluntary National Insurance contributions to fill gaps in your National Insurance record that have arisen over the past six years, with a deadline of April 5th each year. For example, for the tax year 2025/26, you would have until April 5th, 2032, to make a voluntary contribution if you chose to do so.
The rules allow you to purchase a maximum of six qualifying years on your National Insurance record in one go, and those six years are always the six years immediately before the current year.
“Some people don’t realise they can make a voluntary contribution to the UK scheme and that it might bring them up to a better pension in future,” Wickham says.
Mulcahy says: “Once you’ve got over three years of work contributions, you can qualify to contribute on an ongoing basis for the UK National Insurance scheme and get a UK pension.
“It will only cost you about £300 or £400 a year and you get a full year pension,” he says. “You can get a £5,000 or £6,000 pension a year for the price of £300 or £400 a year.”
For this, it does make sense to keep a UK bank account, he says.
A UK state pension will be liable for tax in Ireland if you are resident and domiciled here.