Budget 2027 for Irish Companies: Changes for Non-Resident Owners and Directors

Author: Mark Nathan
Last Updated: 22 October 2026

Budget 2027, delivered on 6 October 2026, changes how Irish companies pay and report some taxes. It does not change the rules that apply to non-resident owners and directors. The EEA-resident director requirement, the beneficial ownership register, dividend withholding tax and the 12.5% corporation tax rate all stay as they were, and the Department of Finance's Tax Policy Changes document, laid before the Oireachtas on 6 October 2026, lists no measure aimed at overseas shareholders or directors.

What the Budget does change is the cash flow and reporting side of running an Irish company, for every owner whatever their country of residence. Most of those changes are announced but not yet law. They depend on the Finance (No. 2) Bill 2026, which had not been published as of publication of this guide, and several also depend on commencement orders or EU approval.

We administer Irish companies for owners based in the US, the UK, the Gulf, India and across the EU. The question those owners ask us after every Budget is what they need to do differently. For most clients this is simply a short list of dates to pay attention to and no change to the structure of their businesses.

What does Budget 2027 change for non-resident owners of Irish companies?

Nothing that is aimed at them specifically. The measures that matter to a non-resident owner are the ones that apply to every Irish company, plus a lower capital gains tax rate that reaches non-residents only in narrow cases.

If you own an Irish company from abroad, we check each of these against your structure when the Finance Bill is published, so you only have to focus on the changes that affect you.

Which Budget 2027 measures affect every Irish company?

Six measures will apply to Irish companies regardless of who owns them.

The Budget also intends to extend the EII, SCI, SURE and Angel Investor reliefs in their current format, subject to adoption of the revised EU General Block Exemption Regulation, which is planned for the end of 2026. None of these changes who can own or direct an Irish company.

How do the preliminary tax changes affect a company with overseas owners?

They change when the cash leaves the company, not how much tax it pays. Preliminary tax is the instalment payment a company makes towards its corporation tax before the return is due. The Department of Finance describes three changes. The existing limited top-up mechanism is extended, so a company meets the requirement by paying at least 80% of its current-year liability by the final instalment date and topping up to 100% within four months of the end of the accounting period. The 45% deeming provision is removed, so an underpaid second instalment no longer creates a deemed underpayment of the first where the first instalment was below 50% of the prior year's liability. And the small company threshold rises from €200,000 to €350,000.

The threshold refers to the corporation tax liability of the prior year, so a company whose liability was a little above €200,000 could fall inside the small company rules, which carry less onerous preliminary tax requirements, once the change becomes law.

For a subsidiary funded by an overseas parent, the practical implication is on cash planning. A smaller payment up front and a balance four months later can reduce how much the parent needs to inject before year end. The budget currently gives no start date, so until the legislation sets one you should treat the current instalment dates as the ones that apply.

Does the new Derelict Property Tax affect overseas owners of Irish property?

It can, because Derelict Property Tax is the one new Budget 2027 tax that attaches to what a company owns and not to what it earns. Revenue will collect it, based on registers of derelict properties that local authorities compile. It applies to residential and non-residential property at 7% of the self-assessed value, and the Department of Finance describes it by reference to the property, with no distinction by the residence of the owner. The legislation will be in the Finance (No. 2) Bill 2026.

A property is treated as derelict if the local authority considers it neither in use nor suitable for use as a dwelling or as a commercial, social or community facility. In the first year the tax covers towns and cities with a population of 4,000 or more (107 towns), and in the second year towns of 2,000 or more (171 towns). The first-year timetable runs as follows.

An owner avoids the tax by remediating the building, demolishing it or selling it to someone who will address the dereliction, and a limited deferral applies to owners who remediate within a reasonable time. If you hold Irish property through a company from abroad, ask whoever manages it whether any building could be classed as derelict before the preliminary registers appear in September 2027. Separately, Residential Zoned Land Tax landowners will get a further opportunity to ask for a change of zoning on the 2027 map and, in some cases, an exemption from the tax for 2027.

Which rules still decide the position of non-resident directors and owners?

The same ones that applied before 6 October. Budget 2027 leaves them in place, and they are where most of the compliance risk for an overseas owner sits.

Do you still need an EEA-resident director?

You do, because section 137 of the Companies Act 2014 requires an Irish company to have at least one director who is resident in an EEA state, or to hold a bond of €25,000 for two years in place of one. The test is where the director lives, not their nationality. The EEA means the 27 EU member states plus Iceland, Liechtenstein and Norway, so a UK-resident or US-resident director does not satisfy it. Nothing in Budget 2027 touches this requirement. Our Section 137 bond service covers the bond, and we can also supply an EEA-resident director where a bond does not suit the structure.

Is dividend withholding tax changing?

Budget 2027 announced no measure on it. An Irish resident company must withhold dividend withholding tax (DWT) at 25% when it pays a distribution, and Revenue lists six categories of non-resident shareholder who can receive the payment without deduction. They include individuals and other non-company persons resident in another EU or EEA state or in a country with which Ireland has a double taxation agreement, and companies resident in those territories that Irish residents do not control.

The exemption is not automatic, and the shareholder gives the company a signed declaration: Form V2A for individuals, V2B for companies and V2C for other bodies of persons. The V2A and V2C forms must be certified by the tax authority of the country where the shareholder lives. A declaration remains valid until 31 December of the fifth year after the year it was issued, so one signed in 2022 expires on 31 December 2027. Revenue's DWT page also links to a consultation on real-time DWT reporting. That consultation is separate from Budget 2027.

We hold the declarations on file for the companies we administer and diarise their expiry dates, which is the step that most often lapses when a shareholder moves country.

Does the lower capital gains tax rate apply to non-resident sellers?

Only if what they sell is within the Irish charge. The standard rate falls from 33% to 31% for disposals on or after 7 October 2026, and development land stays at 33%. A non-resident is chargeable to Irish capital gains tax only on specified assets. These are Irish land and buildings, minerals and exploration rights, assets used in a trade carried on through an Irish branch or agency, and unquoted shares that derive the greater part of their value from land or minerals in Ireland. A non-resident who sells shares in an Irish trading company with no significant land value is generally outside the charge, so the rate cut has no effect on them.

Companies compute their chargeable gains differently from individuals, and the Department of Finance document refers only to the standard rate in section 28(3) of the Taxes Consolidation Act 1997. It does not say how the 31% rate flows into a company's gain, which the Finance Bill should settle.

What happens to the beneficial ownership register and anti-money laundering rules?

Budget 2027 leaves them unchanged, and the filing duties continue as before: the company keeps an internal register of beneficial owners and files the information with the central register at the Companies Registration Office. Separately, the National AML Strategy launched in August 2026 points to more transparency measures, including beneficial ownership disclosure for limited partnerships, and Revenue is due to assess changes to the trust register in the first quarter of 2027. These come from the anti-money laundering programme, not from the Budget. Our guide to Register of Beneficial Ownership filing sets out what the company must hold and file.

Does Pillar Two reach a small foreign-owned company?

Not unless it belongs to a very large group. Pillar Two is the OECD's global minimum tax and applies to multinational groups with consolidated revenue of at least €750 million. Budget 2027 amends the Irish legislation to give effect to the OECD's Side-by-Side Package. The amendments add safe harbours, follow the administrative guidance issued in 2026 and update the filing and penalty provisions. An owner-managed Irish company with a US or UK founder is outside it. A subsidiary of a large group should expect its parent's tax team to follow the Finance Bill closely.

Which other compliance dates should overseas owners put in the diary?

Three compliance changes are worth putting in the diary, and they apply to companies with foreign owners in the same way as to any other.

Employers can use the monthly reporting option for Enhanced Reporting Requirements from January 2027, and the reporting duty itself stays. Professional services withholding tax will move from a flat 20% of the gross payment to personalised deduction rates once the commencement order is made, and it is separate from dividend withholding tax. And under Revenue's e-invoicing roadmap, large corporates must issue structured e-invoices and report invoice data from 1 November 2028, while every VAT-registered business must be able to receive them from the same date. The next phase, in November 2029, extends the duty to VAT-registered businesses trading within the EU. Our VAT guide is updated as the dates firm up.

Table 1 of the Department of Finance document also books €100 million of yield under "Compliance". The document does not describe the measure, so watch Revenue's guidance for it.

What should non-resident owners do before the Finance Bill is published?

Look at the expiry date on every DWT declaration the company holds, and replace any that expire before the end of 2027. Confirm who your EEA-resident director is, or when your Section 137 bond renews. If the company's corporation tax liability sits near €200,000, ask your accountant to model the position under the €350,000 threshold. If you plan to sell Irish land, or a company that holds a lot of it, note that disposals from 7 October 2026 are the ones the 31% rate covers. If you hold Irish property through a company, ask whether any building could appear on a derelict property register from September 2027. Finally, watch Revenue's Budget information page and the Oireachtas site for the Finance (No. 2) Bill 2026, and read the commencement provisions before relying on any date given here.

Our tax and accounting team runs these checks as part of annual compliance for the companies we administer, and a separate review is available for companies we don't.

Frequently asked questions

Does Budget 2027 change corporation tax for foreign-owned Irish companies?

The 12.5% rate on trading income is unchanged. The Budget changes how preliminary tax is paid, raises some R&D credit limits and extends reliefs such as the Knowledge Development Box to 2032, and these apply to foreign-owned and Irish-owned companies equally.

Does Budget 2027 change the rules for non-resident directors?

A company still needs one EEA-resident director or a Section 137 bond. The Budget announced no change to director residency, beneficial ownership filing or the other Companies Act duties of directors.

Is dividend withholding tax changing in Budget 2027?

The Budget announced no measure on it. DWT remains 25%, and non-resident shareholders in the exempt categories still claim relief by giving the company a valid declaration.

Do the new measures apply now, or only when the Finance Bill passes?

Most measures apply only once they are enacted. The capital gains tax cut is stated to apply to disposals from 7 October 2026 and several payroll changes from 1 January 2027, but preliminary tax, the R&D enhancements and professional services withholding tax need the Finance Bill, a commencement order or both. Continue to apply the existing rules until the legislation says otherwise.

Does the lower CGT rate help a non-resident selling shares in an Irish company?

Usually not, because a non-resident is chargeable to Irish capital gains tax only on specified assets. Shares in an Irish company are within the charge only if they are unquoted and derive the greater part of their value from Irish land or minerals.

Does Pillar Two affect a small company with overseas owners?

It applies only to groups with consolidated revenue of at least €750 million. Budget 2027 updates the Irish rules for those groups and does not extend them.

Does the Derelict Property Tax apply to non-resident owners?

The tax applies to residential and non-residential properties that appear on a local authority register of derelict properties, at 7% of the self-assessed value. The Department of Finance describes it by property, not by the owner's residence, and the first pay and file deadline is 23 June 2028.

Where can I check the Budget 2027 measures myself?

Start with the Department of Finance's Tax Policy Changes document for Budget 2027 on gov.ie and Revenue's Budget information page. Both will be updated as the Finance Bill progresses.

Speak to an Irish tax adviser about your structure

Budget 2027 leaves the rules for non-resident owners where they were, and a few new dates arrive with the Finance Bill. A one-hour call with our tax team will tell you which of them apply to your company, what to diarise and whether anything in your structure needs attention before year end.

Book a one-hour tax call

This guide is general information as at 22 October 2026 and isn't tax or legal advice. Budget measures remain subject to the Finance Bill and Revenue guidance.

Sources

• Department of Finance, Budget 2027 Tax Policy Changes
• Department of Finance, Budget in Brief 2027
• Revenue, Dividend Withholding Tax and exemptions for non-residents
• Revenue, Budget information
• Hawksford, Irish Budget 2027: tax, investment and business changes
• Kelmer, Ireland Budget 2027: main tax measures for business
• Dains Ireland, Budget 2027: what actually changed for businesses
• BDO Ireland, E-invoicing
• Companies Act 2014, sections 137 and 138
• Arthur Cox, Ireland launches first National AML Strategy