It is no secret that in certain sectors (such as the financial services, gaming and aviation sectors) the need for highly qualified persons has increased dramatically and the local pool is limited.
Stemming from the importance of these sectors to the country’s economy, a conscious effort has been made to attract highly specialised individuals to the country with the aim of driving these sectors forward.
As a result the ‘Highly Qualified Persons Rules’ were introduced which offer a 15% tax rate on emoluments derived by non-domiciled individuals from a qualifying contract of employment with an entity licensed by one of the Competent authorities as specified in the Rules.
How it works
- 15% flat tax rate charged on gross emoluments up to €5m (without the possibility to claim any relief, deduction, reduction, credit or set-off of any kind)
- No income tax charged on gross emoluments exceeding €5m
- The benefit may apply for a consecutive period of 4 or 5 years (as the case may be) starting from the year during which the person becomes first liable to tax under such Rules
- Beneficiaries are eligible for two extensions of another 4/ 5 years each as the case may be – this is subject to the Rules’s termination date which is currently set to end on 31 December 2025 (but which will likely be replaced by similar rules or extended)
- No change to the individuals’ basis of taxation
The above is subject to the satisfaction of certain conditions and subject to the approval (following a formal application) by the relevant competent authority.
Who may benefit from such Rules – overview of some of the main conditions
- Income from a “qualifying contract of employment”; and
- Received by a “beneficiary”; and
- Consists of “income subject to tax under article (4)(1)(b) of the Act” i.e. employment income; and
- Of a minimum amount which is adjusted annually – which for 2024 amounts to circa €100k; and
- Consists of emoluments from “eligible office”
Certain specific definitions and conditions in terms of the HQPR are attached to the above and therefore it is suggested for the Rules and Guidelines to be looked into properly before submitting an application under these Rules.
Exclusions from the scheme
The Rules and Guidelines also provide for certain specific conditions which, if satisfied, exclude an individual for the reduced rate of tax in terms of the HQPR. These need to be checked on a case-by-case basis.
Penalties (which may be substantial) may apply to a person who applies / applied the benefit when he/ she is not entitled to do so.
How can we help?
Our team of professionals may assist you with identifying whether the HQPR is a right fit for you, support you with applying under such Rules and sorting out any immigration concerns, and provide you with further information or clarifications in respect of the above.
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